Almost every market now requires companies to identify the individuals who ultimately own or control them and to keep that information current with a registry. The thresholds look similar, usually around 25%, but the details differ: who must file, how fast changes must be reported, who can see the register and what happens on failure. The United States has moved the other way, exempting US companies from federal reporting.
Thresholds and definitions
The UK defines a person with significant control as someone holding more than 25% of the shares or voting rights, able to appoint or remove a majority of the board, or exercising significant influence or control; the PSC register is public and can never be blank. Germany uses the same more-than-25% test and, where no individual qualifies, treats the legal representative as the beneficial owner. The UAE test catches a natural person owning or controlling 25% or more. The EU Anti-Money Laundering Regulation adopts 25% or more as the benchmark for ownership interest.
These small differences matter for a group with a shareholder at exactly 25%: that person is a beneficial owner under the UAE and EU benchmark but not under the UK or German more-than-25% test.1234
Speed of updates and access
Singapore companies formed from 16 June 2025 must set up their register of registrable controllers on the day of incorporation, update it within seven days of a change and file the change with ACRA's central register within two business days. UAE companies must report changes to the registrar within 15 days; companies in the financial free zones follow their own regimes and are outside the federal resolution. France's register is no longer open to the public, and since 28 May 2026 failure to file can bring a fine of up to EUR 1,000,000 for the company and a management ban of up to 15 years for its legal representative.56789
The US exception
FinCEN's final rule, effective 14 August 2026, permanently exempts US companies from beneficial ownership reporting under the Corporate Transparency Act. Foreign companies registered to do business in a US state must still report their foreign individual beneficial owners. A non-US group expanding into the US through a foreign branch registration therefore still files, while a newly formed US subsidiary does not.1011
| Market | Threshold | Update deadline or status | Source |
|---|---|---|---|
| UAE (mainland and non-financial free zones) | 25% or more, or control by other means | Changes to the registrar within 15 days; DIFC and ADGM excluded | Cabinet Resolution No. 109 of 2023 |
| Singapore | Registrable controllers | Register on incorporation; central register within two business days of change | ACRA |
| United Kingdom | More than 25%, board control or significant influence | Public PSC register | GOV.UK |
| United States (federal) | Not applicable to US companies | Foreign registered companies still report foreign owners | FinCEN |
| Germany | More than 25% of capital or votes, or comparable control | Transparency Register | GwG s3 |
| France | See market guide | Not open to the public; fines up to EUR 1,000,000 | Service-Public |
| European Union | 25% or more benchmark | Application date not confirmed | Regulation (EU) 2024/1624 |
Decisions to make
- Who are the individuals at the top of our ownership chain, and does anyone sit exactly at 25%?3412The UAE and EU benchmark catches 25% or more; the UK and German tests require more than 25%.
- Who will update the registers when shareholders or controllers change?56Deadlines run from two business days in Singapore to 15 days in the UAE.
- Is the US entity a domestic company or a registered foreign company?1011Only foreign registered companies still report beneficial owners to FinCEN.
- Is the UAE entity in the DIFC or ADGM?7The financial free zones run their own beneficial ownership regimes outside the federal resolution.
Documents usually needed
- Group ownership chart down to natural persons, with percentages and control rights
- Identity documents and residential addresses of beneficial owners
- Shareholder agreements showing board appointment rights or other control
- Internal register of beneficial owners or controllers, with change log
Common mistakes
- Filing the immediate corporate shareholder instead of the ultimate individuals
- Missing short update deadlines after a share transfer or board change
- Assuming the US exemption covers foreign companies registered in a US state
- Applying the UK more-than-25% test in the UAE, where 25% is enough
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- India's significant beneficial owner rules (Companies Act section 90) and Saudi Arabia's beneficial ownership register were not confirmed on official pages.
- The operative article and application date of the EU Anti-Money Laundering Regulation could not yet be checked.
- DIFC and ADGM beneficial ownership regimes were not researched.
- UAE administrative penalties under Cabinet Resolution No. 132 of 2023 were not reviewed.
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.
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.
Reused from market guide claim gb-establish-009.
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.
Reused from market guide claim de-establish-011.
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. Reused from market guide claim ae-establish-007.
The EU Anti-Money Laundering Regulation treats ownership of 25% or more of the shares or voting rights of a corporate entity as the benchmark for beneficial ownership through an ownership interest. Regulation (EU) 2024/1624, recital 107; recital 108 applies the test to direct and indirect holdings. National registers in Germany, France and the UK currently use a more-than-25% test.
Article 52 and the application date in Article 90 were beyond the portion of the page read; the operative wording and start date should be confirmed.
Companies incorporated or registered from 16 June 2025 must set up their register of registrable controllers on the day of incorporation, update it within seven days of a change and file the change with ACRA's Central Register within two business days. Applies to companies (including foreign companies) and LLPs unless exempted. Previously exempted businesses have 60 days after the requirement starts.
Reused from market guide claim sg-establish-010.
Companies must keep a register of beneficial owners and submit any change in beneficial ownership information to the registrar within 15 days of the change. Entities covered by Cabinet Resolution No. 109 of 2023. Administrative penalties for breaches are set by Cabinet Resolution No. 132 of 2023 (not reviewed here).
Reused from market guide claim ae-establish-008.
The beneficial owner resolution does not apply to companies in financial free zones, to companies wholly owned by the federal or a local government (or by their wholly owned companies), or to the government partner where a government is a shareholder. Financial free zones (the DIFC and ADGM) run their own beneficial ownership regimes. Companies owned by a listed company subject to adequate disclosure rules are also exempt from the duty to hold beneficial ownership information.
The resolution says financial free zones without naming them; the DIFC and ADGM are the UAE's two financial free zones. Reused from market guide claim ae-establish-009.
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.
Reused from market guide claim fr-establish-016.
Since 28 May 2026 failure to file beneficial ownership information exposes the legal representative to a fine of up to 200,000 euros and a management ban of up to 15 years, and the company to a fine of up to 1,000,000 euros; the registry may also strike off a company that does not regularise within three months of formal notice. Replaces the former penalties of a 7,500 euro fine and six months' imprisonment (representative) and 37,500 euros (company).
Reused from market guide claim fr-establish-017.
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. Reused from market guide claim us-establish-001.
Foreign reporting companies must still report beneficial ownership information to FinCEN for their foreign individual beneficial owners. Foreign reporting company: an entity formed under foreign law that has registered to do business in a US state or tribal jurisdiction. US person beneficial owners are not reported.
Reused from market guide claim us-establish-002.
Questions on this topic
11 statements on beneficial ownership registers
