Most of the European Union member states have by now established their register of beneficial owners of legal entities (in short: UBO register) as was made obligatory under the 4th Anti-Money Laundering Directive. Making the UBO register public was subsequently made obligatory under the 5th Anti-Money Laundering Directive however, not all of the registers in the EU member states are publicly accessible yet. Also several problems with quality and completeness of the UBO registers have been pointed out (such as in relation to the OpenLux investigation).
Nonetheless the available registers are becoming an increasingly relevant source for investigations and due diligence. While I did find quite some articles on the legal side of the UBO registers in various EU member states, I have not found any (complete) overview of online access to the actual UBO registers in the EU member states. Therefore I went to find them for myself and meanwhile test them on usability. NB: along the way I’m also adding the UBO registers I find in neighbouring other European countries.
In this blog post I detail the findings of that research. I will provide overall descriptions of the registers and, where available, I will provide the direct link to the online source. I’m still in the process of actually testing the registers to see whether an account is needed, what the fees are, what access requirements are and in which language(s) the interface and data is available. Therefore this page may see some updates over time.
The post is last updated on 21 March 2021
Before I go into the UBO registers in the individual EU member states, I would first like to point out the OpenOwnership project which collates UBO information from different sources. It has currently data from Denmark, Slovakia, the UK and Ukraine in the register. And all the data is downloadable as well. This is a brilliant initiative which – I hope – eventually would have the data from all registers collated in one database.
I realise that there is always a downside to using ‘second-hand’ data and therefore we do also need to understand the original sources as well.
Since 10 January 2020, das Register der wirtschaftlichen Eigentümer (WiEReG) is (also) open to the public and can be accessed directly via the website of the Federal Ministry of Finance. All in German only. A fee of 3 euro is charged with is payable by credit card. Searches on the name do not always work, however it is also possible to search by company registration number (‘Stammzahl’).
The UBO register is maintained by the Ministry of Finance and access is only possible with a Belgian e-identity or with a European eIDAS (though limited to 10 other EU member states as yet). I have not been able to verify if and how it works myself.
Bulgaria does not maintain a separate UBO register, however has it integrated the UBO data in its trade register. When searching the register, which is free, can be done without account but is in Bulgarian only, an extra menu option shows the ‘Действителни собственици’ or ‘Actual owner’.
The Croatian UBO register (in Croatian: Registar stvarnih vlasnika (RSV)) is established as a separate register maintained by the Croatian Financial Agency (FINA). Access is available online, however is only possible with identification via the Croatian National Identification and Authentication System. That system so far only accepts Croatian personal or business identification credentials.
It appears there are two UBO registers. The fist relates to the existing companies register and will contain the UBO information for companies. Access to the UBO information is restricted to authorities and entities obliged to perform due diligence and customer identification measures as laid down in the AML legislation. Others should demonstrate a legitimate interest and may be given access to the name, month and year of birth of the UBO, as well as, the country of residence.
UBO information in relation to trusts will be kept by the Cyprus Securities and Exchange Commission (CySEC) however that register appears not to be accessible yet.
The Czech Republic UBO register (evidence skutečných majitelů) is not publicly available.
Denmark has already for years, like the UK, one of the easiest accessible corporate registers where also the UBO information is collated. Information about ownership is publicly available without restriction, also in English. Anyone can look up a company/entity and see who the registered owners are, and anyone can look up a person and see for which companies the person is registered as an beneficial owner.
Information on UBOs of Estonian companies is publicly available at the website of the Estonian Commercial Register. The register is available in English and for 1 euro the data on UBO’s of a company is provided. Pro-tip 1: go also for the ‘documents in the business file’ and buy for 2 euro the original documents which usually provide more detailed information (such as passport numbers). Pro-tip 2: the register can also be queried by UBO, if you have the name, date of birth and country of origin.
The Patent and Registration Office maintains the UBO register as part of the Trade Register. However, the details on beneficial owners are not public in the same way as other company details entered in the Trade Register. The information about whether the notification of beneficial owners has been registered is public. However access to details is only possible for:
- Finnish supervisory authorities defined in the Act on Money Laundering;
- companies defined in the Act on Money Laundering who have an obligation to know their customers (such as banks, insurance companies and other financial institutions, real estate agents, auditors);
- media representatives; and
- other parties whose purpose of use of the details is in accordance with the Act on Money Laundering.
So for media purposes, and likely for due diligence purposes, it is possible to obtain the details from the UBO register, although the party requesting the details must report the intention for which the details will be used by submitting a form the Trade Register has drawn up for this purpose. Also the identity of the requestor is verified. I have not tried this myself.
In France the ‘Registre des bénéficiaires effectifs‘ is maintained by the Register of Trade and Companies (RCS). When searching a company in the register, the data on UBOs can be obtained via a simple link. However, an account is needed and access to the UBO information will only provided to the relevant authorities or to entities which are under obligation to verify their clients as part of their AML compliance, so the register is not really public.
In Germany the UBO register is called ‘Transparency register‘. Registration is needed and a valid ID should be uploaded. When requesting data a legitimate interest should be demonstrated, however this could also be as a member of general public. (I have not tested it all the way so an update will follow here).
Technically also not EU anymore (like the UK), however it is an interesting jurisdiction to add here. The UBO register can be searched via this link. If you’re not a Gibraltar resident, you’ll need to create an account, which actually works straightforward. After that you (as a ‘member of the public’) can obtain the following information of the UBOs: name, the month and year of birth, the nationality, the country of residence and the nature and extent of beneficial interest of the UBO. A fee of 2,5 GBP is charged per search, payable by creditcard.
In Greece the UBO register is euphemistically named the ‘Real Beneficiaries Register’ register. Full acces to the register is available for authorities and financial institutions with a due diligence obligation, while limited access is available for the general public. Online access to the register is available via the GSIS website and appears to be available in Greek only. An account is needed.
As of 1 december 2020 the obligation to provide information on UBOs exist, but a working register is not expected before spring 2021. The name will be ‘Tényleges tulajdonosi információk központi nyilvántartása’ and to my understanding only with a demonstrable legitimate interest access will be possible.
The Icelandic word for UBO is ‘Raunverulegur eigandi’ and the data can be obtained from the website of the company register. No account is needed and no fees are charged. The name, month and year of birth and extent of the ownership is provided. In Icelandic only so the automated translation function of the Chrome browser is quite helpful.
The website of the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies is available online. Unrestricted access to all data is reserved for the authorities, the general public can obtain certain information from the register. An account is needed and a € 2,50 fee for each UBO is charged.
The Register of Beneficial Ownership of Financial Vehicles (e.g. trusts) is currently being filled and should become accessible in Spring 2021.
No (online) UBO register yet implemented.
The UBO register of Latvia, can be found at Latvijas Republikas Uzņēmumu reģistrs and provides full access to the UBO data, free from fees and in English.
UBO data in Lithuania is collected in the Juridinių asmenų dalyvių informacinės sistemos (JADIS) which also holds the register of legal entities. For direct access to the system a Lithuanian e-Identity / digital signature is required so I have not been able to test this.
The UBO register in Luxembourg is called the ‘Register des Bénéficiares Effectifs’ (RBE). The introduction of the UBO register has led to a modernisation of the Luxembourg Business Registers (LBR) website and from the startpage of the LBR the choice can be made to access the RBE. Access is available for everyone without an account and free of charge.
On Malta the UBO information is collected by the Mala Business registry and is easy and freely searchable. The register also has a link via which Beneficial Owners can be searched by individual. While that sounds nice, you do need to provide the ID/Passport Number with the name, which is information that is mostly not public.
The register is available via the corporate register. Registration is needed, but there are no further restrictions. There is no need to demonstrate a legitimate interest. The fee for an extract from the register is 2,50 euro, which can be paid via creditcard. Note that many organisations have not yet submitted their UBO data and have the time to do that till March 2022.
The UBO register in Poland is named Centralny Rejestr Beneficjentów Rzeczywistych (CRBR) and has been operating since October 2019. It is hosted by the Ministry of Finance and is freely accessible for everyone via this website. But brush up your Polish (or use the automatic translation function in Chrome which works amazingly well).
The Portugese UBO register is called the Registo Central de Beneficiário Efetivo (RCBE) and is maintained by the Ministry if Justice. While the register can be consulted online, a Portugese Citizen Card or Digital Mobile Key is needed to consult the register.
The Romanian UBO register, or ‘Registrul Beneficiarilor Reali’ is accessible via the Romanian Ministry of Justice Official National Corporate Register (‘Registrul Comerțului’) portal or ONRC. An account is needed however that is easy set up. The information on the UBO then has to be requested through an online form in which all details of the requester should be provided. After payment of a fee of 4 euro (by credit-card) the form can be submitted and the information will be received. I have not tested the full procedure yet.
The UBO register in Slovakia is called the Register partnerov verejného sektora (Register of public sector partners) and is freely searchable via a webpage of the Ministry of Justice. The information is immediately available without any fees. In Slovak only though. Also available via open ownership.org.
In Slovenia UBO data is accessible via the website of the Agency of the Republic of Slovenia for Public Legal Records and Related Services (Agencija Republike Slovenije za javnopravne evidence in storitve) or in short ‘AJPES’. The database can searched in English and the information is freely available.
UBO information from Spanish companies can be obtained via the corporate register. After finding the company, a ‘Certificación de titularidad real‘ (Certificate of real owner) can be ordered. However, either an account is needed (with a 150 euro deposit) or the data can be accessed using a digital identification certificate. And although I have one which should work, I have not been able to access the data yet. So, still researching.
In Sweden the UBO register (registret över verkliga huvudmän) is maintained by the Swedish Companies Registration Office (Bolagsverket). The database can be searched in English and information from the UBO register is available to buy online for SEK 250. However, an account should be made for which a Swedish personnummer is needed. Obviously I do not have such a number, however I found one on the Web and currently testing whether it will be accepted…..
Not EU, but hey, surrounded by the EU so let’s include them. The word for UBO in Switzerland is ‘wirtschaftlich berechtigte Person‘, however I’m not really confident on the actual register. The data should be somewhere behind the central company index, Zefix (or Zentraler Firmenidex) however, I’m still researching this one.
Yes, I know, the UK is not EU anymore. However UK entities, and in particular the Limited Partnerships, are still a much used vehicle for money laundering. So having them included here does serve a purpose.
The UK Persons with significant control (PSC) register has been in place for a number of years now and is freely searchable from in the Companies House data for legal entities under the tab ‘People/Persons with significant control’. Also Companies House provides the original source data in a downloadable full list of PSCs provided to Companies House (unzipped currently a 6.21 Gb text file).