Before appointing a distributor, agent or supplier, a business needs to know who it is dealing with: whether the company exists, who runs it and who ultimately owns it. Public registries answer the first two questions in most markets, but access to beneficial ownership data now varies sharply. Since the EU Court of Justice ruling of November 2022, EU registers are no longer open to everyone, and in the UAE and India ownership data are held for authorities and regulated firms rather than the public.
What company registries show
Commercial registers are the starting point. In the UK, Companies House gives free access to a company's registered address, date of incorporation, current and resigned officers, filed documents, charges, previous names and insolvency information. Its register of people with significant control, meaning those holding more than 25% of shares or votes or exercising significant control, is public. Since 18 November 2025 directors and people with significant control must verify their identity with Companies House, which improves the reliability of new filings.
In Germany anyone may inspect the commercial register and the documents filed with it for information purposes. These public registers show legal existence and officers; they do not prove solvency, reputation or that the person you are negotiating with has authority, so extracts should be read against signed corporate documents.1234
Beneficial ownership after the 2022 EU ruling
On 22 November 2022 the Court of Justice of the EU, in joined cases C-37/20 and C-601/20, invalidated the rule requiring EU beneficial ownership registers to be open to any member of the public. Member States restricted access in response. France's register is no longer open to public consultation and access depends on a legitimate interest in combating money laundering. In Germany the Transparency Register is open to authorities, to obliged entities for their due diligence, and to anyone else only on proof of a legitimate interest; where access is granted it shows name, date of birth, residence, the nature and extent of the interest and nationalities.
The sixth Anti-Money Laundering Directive (EU) 2024/1640 rebuilds access around legitimate interest. Its recitals say this should be presumed for journalists, academics and civil society, and that people who may do business with or invest in an entity should not be excluded; they set 10 July 2026 for transposing these provisions. Whether a prospective commercial partner can now obtain access in each Member State depends on national implementation, which should be checked before relying on it.5678910
Ownership thresholds and access outside the EU
Thresholds differ. Germany treats as a beneficial owner anyone holding more than 25% of capital or votes; the UAE uses 25% or more; Indian anti-money laundering rules use more than 10% for client due diligence by banks and other reporting entities. In the UAE the ministry and registrar may not disclose beneficial owner or shareholder register data without written approval, except to authorities and under international obligations, so a private counterparty cannot simply look it up. In the US, FinCEN's final rule from 14 August 2026 exempts US companies from beneficial ownership reporting altogether.
In practice, where registers are closed, ownership has to be established from the counterparty itself: certified registers of shareholders, organisation charts and declarations, supported by your bank's or adviser's due diligence.1112131415
| Market | Company register | Beneficial ownership threshold | Who can see beneficial ownership | Source |
|---|---|---|---|---|
| United Kingdom | Companies House: free basic details, officers, filings | More than 25% (PSC) | Public PSC register | GOV.UK |
| Germany | Handelsregister open to anyone | More than 25% | Authorities, obliged entities, others with proven legitimate interest | GwG ss. 3, 19, 23; HGB s. 9 |
| France | Not researched here | Not researched here | Authorities and obliged professionals; others with legitimate interest, case by case | service-public.gouv.fr |
| UAE (mainland and non-financial free zones) | Not confirmed | 25% or more | Authorities; otherwise only with written approval | Cabinet Resolution 109 of 2023 |
| India | Not confirmed | More than 10% for client due diligence | Reporting entities under AML rules; public register not confirmed | PML Rules 2005 |
| United States (federal) | State-level registries | Not applicable to US companies | US companies exempt from FinCEN reporting from 14 August 2026 | FinCEN |
Decisions to make
- Can you see the counterparty's beneficial owners in a public register, or must you rely on its own declarations?521413EU, UAE and Indian ownership data are restricted; the UK PSC register remains public.
- Do you, or your adviser, qualify for access to an EU register through a legitimate interest?7910Germany requires proof of legitimate interest, and new EU rules presume it for some groups and protect prospective business partners.
- Which ownership threshold applies in the counterparty's market?111213A 15% holder is a beneficial owner for Indian client due diligence but not under the German or UAE tests.
- Has identity verification been completed for the counterparty's UK directors and PSCs?3Verification has been a legal requirement since 18 November 2025 and gaps may signal filing problems.
Documents usually needed
- Current register extract (commercial register or Companies House record) dated within the last few weeks
- Certified register of shareholders and ownership chart up to the ultimate individuals
- Beneficial ownership declaration signed by the counterparty, with supporting evidence
- Transparency Register or RBE extract where access has been granted
- Board resolution or power of attorney showing the signatory's authority
Common mistakes
- Assuming EU beneficial ownership registers are still open to the public after the November 2022 ruling
- Relying on a registry extract alone without seeing the shareholder register and signatory authority
- Applying a 25% test everywhere when India uses more than 10% for client due diligence
- Expecting UAE mainland ownership data to be obtainable on request by a private business
- Treating a clean register record as evidence of solvency or reputation
Questions businesses ask
Can I still search the German Transparency Register?
Only if you are an authority, an obliged entity acting for due diligence, or can prove a legitimate interest to the registry. The commercial register itself remains open to everyone.74
What changed with the 2022 EU court ruling?
The Court of Justice invalidated the requirement for beneficial ownership information to be accessible to any member of the public in all cases. EU law now builds public access around legitimate interest.59
Is the UK PSC register still public?
Yes. Companies keep their PSC information at Companies House, and it is public.2
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- India's MCA company master data service could not yet be checked, so what the public can see about Indian companies and charges is not confirmed here.
- UAE commercial licence lookups (the National Economic Register and emirate economic departments) and DIFC and ADGM registers were not researched.
- Saudi Arabia's commercial register and its public search were not researched.
- Whether Singapore's register of registrable controllers is accessible to private parties could not be confirmed on the ACRA pages read.
- Articles 11 and 12 of Directive (EU) 2024/1640 and German and French transposition of the legitimate-interest rules could not yet be checked; the July 2026 date comes from the recitals.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Companies House lets anyone get some company details free, including registered address and date of incorporation, current and resigned officers, document images, mortgage charge data, previous company names and insolvency information. UK companies on the Companies House register.
A person with significant control is someone who holds more than 25% of the shares or voting rights, can appoint or remove a majority of the board, or exercises significant influence or control. Companies keep a PSC register at Companies House that is public and can never be blank; changes are generally reported within 14 days.
Identity verification for directors and people with significant control became a legal requirement at Companies House on 18 November 2025. Introduced under the Economic Crime and Corporate Transparency Act 2023. New incorporations must include each director's Companies House personal code.
Anyone may inspect the German commercial register (Handelsregister) and the documents filed with it, for information purposes, by individual electronic retrievals. Federal; section 9(1) of the Commercial Code (HGB). The Länder designate the electronic system used.
On 22 November 2022 the Court of Justice of the EU, in joined cases C-37/20 and C-601/20, held Article 1(15)(c) of Directive 2018/843 invalid in so far as it required beneficial ownership information to be accessible in all cases to any member of the general public. EU Member States' central beneficial ownership registers. The ruling removed the EU-law basis for unrestricted public access; access by authorities and obliged entities was not affected.
The beneficial ownership register (RBE) is no longer open to public consultation; access is limited to persons showing a legitimate interest in combating money laundering, assessed case by case, while authorities and AML-obliged professionals keep full access. Those with a legitimate interest see limited data such as name, month and year of birth, nationality and nature and extent of interest.
In Germany, the Transparency Register may be inspected by authorities and courts for their statutory tasks, by obliged entities that explain the access serves their customer due diligence, and by anyone else only if they prove a legitimate interest to the registry. Federal; section 23(1) of the Money Laundering Act (GwG). Details of the demonstration requirements can be set by Federal Ministry of Finance regulation.
Where the German Transparency Register is accessible, it shows a beneficial owner's first and last name, date of birth, place of residence, nature and extent of the economic interest, and all nationalities. Federal; section 19(1) GwG, subject to the access rules in section 23.
Directive (EU) 2024/1640 makes public access to beneficial ownership registers depend on a legitimate interest, which should be presumed for non-governmental organisations, academics and investigative journalists, and persons who may do business with or invest in an entity should not be excluded from having one. EU Member States. Providers of customer screening products may also have a legitimate interest, but only to supply the data to obliged entities and competent authorities.
Taken from the recitals; the operative Articles 11 and 12 were not reached because the page text was truncated.
The recitals of Directive (EU) 2024/1640 state that Member States should transpose the provisions on legitimate-interest access to central beneficial ownership registers by 10 July 2026. EU Member States. How Germany and France have implemented the new access rules was not confirmed.
Article 74 (transposition) could not yet be checked; the date is taken from recital 135.
A beneficial owner of a company is any natural person who directly or indirectly holds more than 25 percent of the capital, controls more than 25 percent of the voting rights or exercises comparable control; if none can be identified, the legal representative or managing partner is deemed the beneficial owner. Companies other than registered foundations and listed companies subject to equivalent transparency rules.
A beneficial owner is a natural person who owns or ultimately controls a legal person directly or indirectly through 25% or more of the ownership, or who controls it by other means such as the right to appoint or remove most directors. Mainland and non-financial free zone legal persons. Excluded entities are set out in ae-establish-009. Where no person meets the test, the resolution provides fallback rules.
Cabinet Resolution No. 109 of 2023 replaced Cabinet Resolution No. 58 of 2020. JAFZA's guidance gives 15 December 2023 as its effective date; the resolution itself says it takes effect the day after Official Gazette publication.
For client due diligence, a beneficial owner of a company is a natural person who, alone or with others, has a controlling ownership interest of more than 10% of the shares, capital or profits of the company. Rule 9(3)(a), PML (Maintenance of Records) Rules 2005; partnerships also use 10% and unincorporated associations 15%. Central rule.
Other limbs of the definition (control through other means, senior managing official) were not checked.
Under the UAE beneficial owner resolution, the Ministry and the registrar may not disclose data in the beneficial owner register or the partners or shareholders register without written approval, except for disclosures the resolution itself requires and under international laws and agreements in force in the UAE; the registers are provided to relevant UAE authorities on request. Federal; mainland and non-financial free zone legal persons covered by Cabinet Resolution No. 109 of 2023. The ministry must also facilitate access by competent foreign authorities to basic data. There is no general public access.
Read in the official English translation. Financial free zones (DIFC, ADGM) run their own regimes, which were not researched.
FinCEN's final beneficial ownership information (BOI) rule, effective 14 August 2026, permanently exempts US companies from BOI reporting and removes the need to report US persons as beneficial owners. Federal rule under the Corporate Transparency Act. Applies nationwide; makes permanent the exemptions first introduced by the interim final rule of 26 March 2025.
Final rule published in the Federal Register on 14 August 2026 (document 2026-16576); the Federal Register page was seen in search results but not yet checked.
Questions on this topic
15 statements on company and counterparty checks
