Sanctions News Desk · KYB and UBO · Guide

    An EU court ruling of 22 November 2022 ended the duty to open beneficial-owner registers to all, so finding a company's UBO depends on where it is registered

    A company's ultimate beneficial owner is always a person, and the place to find that person depends on the country. The UK publishes its register of people with significant control, and Poland describes its register as free to anyone. Elsewhere in the EU, a Court of Justice ruling of 22 November 2022 ended the rule that beneficial-ownership data must be open to every member of the public. Directive (EU) 2024/1640 gives access to anyone with a legitimate interest, a group that Member States had to extend by 10 July 2026 to a person likely to enter into a transaction with the company.

    By ScreenVeritAI Team, Sanctions News Desk

    Key facts

    • Who a UBO is: Always a natural person; a parent company is never the answer
    • Ownership threshold: More than 25 percent today; 25 percent or more from 10 July 2027, with indirect stakes multiplied along the chain
    • Open EU registers: No longer required since the Court of Justice ruling of 22 November 2022
    • Access for counterparties: People likely to enter into a transaction with a company count as having a legitimate interest
    • United States: US companies and US persons no longer report beneficial ownership to FinCEN

    Short answer

    Look up the company in the beneficial-ownership register of the country where it is incorporated, then trace any company you find there up to the people who own or control it. The UK publishes its register of people with significant control, and Poland's Ministry of Finance says its central register is free to anyone. Elsewhere in the EU you may have to show a legitimate interest, and someone likely to enter into a transaction with the company qualifies under Directive (EU) 2024/1640. The register is where the work starts. If you are an obliged entity, the law says it cannot be where the work ends.

    A beneficial owner is always a person

    The current EU rule is in Article 3(6) of Directive (EU) 2015/849. A beneficial owner is the natural person who ultimately owns or controls the customer. For companies, a shareholding of 25 percent plus one share, or an ownership interest of more than 25 percent, is "an indication" of ownership. The same stake held through a company that a person controls is an indication of indirect ownership. Member States may set a lower percentage.

    Ownership is only half of the test. Control by other means counts too, and the directive points to Article 22 of the Accounting Directive (2013/34/EU) for the tests of when one undertaking controls another. A company listed on a regulated market with EU-standard disclosure rules is excluded from the test.

    When no one qualifies, the directive has a fallback. If, after exhausting all possible means and with no grounds for suspicion, no owner can be identified, or there is doubt about the one found, the senior managing official is recorded instead. The obliged entity must keep records of what it did to look. A managing director in that slot is a placeholder, not an owner.

    The UK uses the same idea with different wording. Companies House calls these people PSCs. A PSC is usually anyone who holds more than 25 percent of the shares or voting rights, can appoint or remove a majority of the directors, or can otherwise influence or control the company. The register records each stake in bands: over 25 percent up to 50, over 50 and under 75, and 75 percent or more.

    The 25 percent rule gets a formula on 10 July 2027

    From 10 July 2027, Regulation (EU) 2024/1624 replaces the directive's definition, and Article 52 states the arithmetic. The threshold becomes 25 percent or more. Indirect ownership is calculated by multiplying the stakes held along each chain of companies and adding the chains together, and every level of ownership counts.

    Take one structure. A target company's two largest shareholders are a holding company with 50 percent and a person, Y, with 10 percent. The holding company is owned 60 percent by person X and 40 percent by Y.

    PersonThrough the holdingDirectTotal under Article 52
    X60% × 50% = 30%none30%
    Y40% × 50% = 20%10%30%

    Both are beneficial owners from 10 July 2027. Under the current directive the picture is less tidy. X controls the holding company, so its 50 percent stake is an indication that X owns indirectly. Y does not control the holding, and the directive gives no formula for her 20 percent through it. The regulation's multiplication removes the ambiguity, so a structure that showed one clear beneficial owner may show two after the change.

    Where the registers are, and who may look

    SourceWhat you getWho can see it
    UK Companies House, PSC registerName, nature of control, ownership band; the home address is never publishedPublished on the Companies House register
    Poland, CRBRBeneficial owners of Polish entitiesFree to anyone, according to the Ministry of Finance
    Other EU national registers, linked through BORISName, month and year of birth, residence, nationality, nature and extent of the interestNational rules; from 10 July 2026, at least people with a legitimate interest
    GLEIF Level 2 dataDirect and ultimate accounting parent of companies that hold an LEIFree, no registration
    US FinCEN beneficial ownership reportingFiled only by foreign companies registered to do business in a US state or Tribal jurisdiction; the exemption for US companies became permanent on 14 August 2026FinCEN's page describes how to file, not how to search

    The EU row changed in 2022. Directive 2015/849, as amended in 2018, required that beneficial-ownership information be accessible in all cases to any member of the general public. On 22 November 2022, in Joined Cases C-37/20 and C-601/20, the Court of Justice declared that amendment invalid. The ruling removed the obligation. It did not by itself close any register, and the Polish Ministry of Finance page, last modified on 11 August 2023, still calls the register public and free to anyone. It covers most Polish company forms, from general partnerships to joint-stock companies, as well as cooperatives, registered associations, foundations and some trusts. Public companies under Poland's 2005 public offering act are left out, the same carve-out for listed companies that the directive makes.

    Directive (EU) 2024/1640 set the new floor. Article 12 gives access to anyone who can demonstrate a legitimate interest in preventing money laundering, and it lists who is deemed to have one. Journalists and civil society organisations working on the subject are on that list, and so are "natural or legal persons likely to enter into a transaction with a legal entity" who want to keep that transaction clean. Member States had to transpose that article by 10 July 2026. A company vetting a new supplier is the case the clause describes.

    BORIS, on the European e-Justice Portal, links the national registers. Use it to find the right one; the entries themselves sit in the national registers.

    GLEIF is the free map of corporate chains. Companies with a Legal Entity Identifier report their direct and ultimate accounting consolidating parent, and the whole data pool can be searched free of charge without registration. An ultimate parent is still a company, and the people who own or control it remain to be found.

    The United States is the gap. On 21 March 2025 FinCEN announced an interim final rule that exempted every company created in the United States, and every US person, from beneficial-ownership reporting. A final rule issued on 11 August 2026, in force since 14 August 2026, made that permanent. Only foreign companies registered to do business in a US state or Tribal jurisdiction still report, and they need not name US persons as owners.

    A check on one company, step by step

    Suppose a prospective supplier sends you its name and a registration number. The order that wastes least time:

    1. Fix the jurisdiction. The registration number tells you which national register to open first.
    2. Pull the register entry. Note each declared beneficial owner or PSC, the nature of control and the band or percentage. In the UK, Companies House also tells you when a company says it has no PSC, and it requires a statement explaining why.
    3. Follow every company upwards. For each corporate shareholder, open the register of its own jurisdiction and repeat. If the shareholders hold LEIs, GLEIF's Level 2 data shows the accounting parents and saves a step, though it will not name a person.
    4. Do the arithmetic. Multiply along each chain, add the chains, and compare the result with the threshold. Then look for control without shares: Companies House points to the register of members and to the articles of association, which can hold voting and other rights.
    5. Compare and record. Set what the registers say beside what the supplier told you. Where they differ, that is a discrepancy to resolve and, for an obliged entity, to report. Write down which registers you opened and on what date, because the directive's fallback to a senior managing official only stands if you can show what you tried first.

    When you have names, screen them. A beneficial owner can be a politically exposed person or a sanctioned one even when the company is neither; our guide on how to check if someone is a PEP covers the next step.

    What a register entry does not prove

    A register entry is a declaration by the company. Article 30(8) of the directive tells obliged entities not to rely exclusively on the central register, and Article 30(4) requires them to report discrepancies between the register and what they find. When the paper trail and the register disagree, the disagreement is itself a finding.

    The UK puts weight behind the declaration. A company that believes it has a PSC whose details it lacks should send that person a notice, and Companies House says anyone who does not respond within one calendar month, or gives false information, commits a criminal offence that can bring a two-year prison sentence, a fine or both. A declaration backed by a penalty is still only a declaration, but it is one somebody had reason to get right.

    Some registers are getting harder to fool. Identity verification with Companies House became a legal requirement for directors and PSCs on 18 November 2025. Existing directors supply their personal code with the next confirmation statement, and each PSC has a 14-day window, so the register is still being tied, name by name, to checked people. Verification does not make the declared structure true, and nominee arrangements and control by other means still need their own evidence.

    The free route works when the chain is short and stays inside open registers. It breaks at a jurisdiction with no public register, at a trust, or at a holding company whose own owners are not declared anywhere you can reach.

    ScreenVeritAI's KYB and UBO research maps the ownership and control records it can support with sources, names beneficial owners where reliable sources allow and keeps unresolved gaps visible for an analyst. It then screens the people it surfaces against sanctions, PEP and criminal watchlists, because a company with no sanctions match can still have an owner who has one.

    What this guide does not cover

    This guide covers finding the beneficial owners of companies. Trusts and foundations have their own lists of beneficial owners under the directive, including settlors, trustees and beneficiaries, and are not worked through here. National access rules after 10 July 2026 differ by country and were not checked register by register. The thresholds, dates and access rules are quoted from the texts listed below as they stood on 1 October 2026.

    Frequently asked questions

    Where can I find out who owns a company for free?

    Start with the national register where the company is incorporated. The UK publishes people with significant control on the Companies House register, and Poland's Ministry of Finance describes its central register as free to anyone. Other EU registers may ask you to show a legitimate interest; a prospective business partner is one of the groups the 2024 directive names.

    GLEIF shows me an ultimate parent. Is that the beneficial owner?

    No. A beneficial owner is a natural person. GLEIF's free Level 2 data shows the direct and ultimate accounting parent of companies that hold an LEI, which is a useful map of the chain, but you still have to find the people at the top of it.

    What if nobody owns more than 25 percent?

    Look for control by other means, such as the right to appoint most directors. If after exhausting all means no one qualifies, the current directive points to the senior managing official, and it requires you to keep records of the steps you took.

    My customer holds 20 percent through a holding company and 10 percent directly. Is she a beneficial owner?

    From 10 July 2027, yes. The EU regulation spells out the arithmetic: multiply the stakes along each chain of companies and add the chains together. Someone with 20 percent through a holding and 10 percent directly reaches 30 percent.

    The company sent me its register extract. Is that enough for customer due diligence?

    Not if you are an obliged entity in the EU. The directive says you must not rely exclusively on the central register, and it requires you to report discrepancies between the register and what you have found.

    Sources

    1. Directive (EU) 2015/849, consolidated text of 30 June 2021 — EUR-Lex, October 1, 2026
    2. Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing — EUR-Lex, October 1, 2026
    3. Directive (EU) 2024/1640 on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing — EUR-Lex, October 1, 2026
    4. Judgment of the Court (Grand Chamber), 22 November 2022, Joined Cases C-37/20 and C-601/20, WM and Sovim SA v Luxembourg Business Registers — EUR-Lex, October 1, 2026
    5. People with significant control (PSCs) — Companies House, GOV.UK, October 1, 2026
    6. Verifying your identity for Companies House — Companies House, GOV.UK, October 1, 2026
    7. Centralny Rejestr Beneficjentów Rzeczywistych — Ministry of Finance of Poland, October 1, 2026
    8. Beneficial ownership registers interconnection system (BORIS) — European e-Justice Portal, October 1, 2026
    9. Level 2 Data: Who Owns Whom — GLEIF, October 1, 2026
    10. Beneficial Ownership Information Reporting (final rule of 11 August 2026) — FinCEN, October 1, 2026
    11. FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons — FinCEN, October 1, 2026

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    Informational analysis of published regulatory sources. Not legal advice. Verify the primary sources before acting.