UBO register
EU-wide register of ultimate beneficial owners under the 4th, 5th, and 6th AMLD.
| EU (AMLD) | UBO register |
|---|---|
| Germany | Transparenzregister (since 2017) |
| Netherlands | UBO register at KvK (since 2020) |
| France | Registre des Bénéficiaires Effectifs (RBE) |
| UK | PSC register (People with Significant Control) |
What gets reported
For each UBO, the register typically holds: full name, month and year of birth, nationality, country of residence, the nature and extent of the beneficial interest. The 25% ownership or control threshold is the standard trigger, with adjustments by member state for specific entity types or industries.
Public access varies after the Court of Justice ruling
Until November 2022, EU UBO registers were generally accessible to the public. After the Court of Justice of the European Union (CJEU) ruled in WM and Sovim v Luxembourg that public access without proper justification violates fundamental rights, member states have restricted access. Today, access typically requires demonstrating a legitimate interest (e.g., journalists, civil society organizations, obliged entities under AML rules).
Filing obligations and penalties
Each member state imposes its own filing obligations. Typical requirements: file initial UBO information within a defined period of incorporation; update within a short window after any change (often 30 days); confirm annually that the register is current. Penalties for non-compliance range from administrative fines to criminal liability in some member states.
Octelligence flags beneficial-owner thresholds based on the share register and supports structured records for UBO register filings across multiple EU member states. EU data residency.
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