Beneficial ownership, country by country

UBO register: who can see the owner of your company

Updated 13 November 202628 registers comparedAbout 13 minutes to read
The short answer

A UBO register is an official record of the living people who ultimately own or control a company, usually anyone with 25% or more, or the power to control it in another way.

Almost every country now keeps one. The real difference is who may look: anyone, people with a legitimate interest, banks, or only the authorities. Of the 28 registers below, two are open to the public.

Of the 28 we compare 2 registers that anyone can search for a company's owner The UK's PSC register and Gibraltar's register of ultimate beneficial owners. The rest open only to people with a legitimate interest, to banks, or to the authorities.

If you own a company, your name is on at least one beneficial ownership record somewhere, even if the company is in a place famous for privacy. That is not a problem in itself. What you want to know is where that record sits, who can open it, and what happens if you file it late. This page answers all three for every register Heirson works with, from the law or the registry itself.

Key takeaways

  • FATF Recommendation 24 requires every country to make owner data available to authorities "rapidly and efficiently". Public access is optional, and most places chose not to offer it.
  • The EU's open registers ended with the CJEU ruling of 22 November 2022. Access now runs through a legitimate interest test, with answers due within 12 working days from 10 November 2026.
  • The UK PSC register stays fully public, with home address and full date of birth hidden.
  • Since March 2025, companies formed in the US don't report owners to FinCEN. Only foreign companies registered in a state do, within 30 days.
  • Several offshore centres use a 10% threshold, not 25%: the BVI (for filing), Seychelles, Bahamas, Belize and Bahrain.
  • Deadlines run from 14 to 30 days in most places, and late filing fines are counted monthly or daily.
Chapter 1

What is a UBO register?

The ultimate beneficial owner (UBO) is the natural person at the end of the chain: not the nominee shareholder, not the holding company, but the human who owns or controls it. A UBO register, also called a beneficial ownership register, PSC register, register of significant controllers or transparency register, is the official list of those people for each company. The glossary entry has the short version.

Registers exist because of FATF Recommendation 24, revised in March 2022. It requires "adequate, accurate and up-to-date information on the beneficial ownership and control of legal persons" that authorities can obtain "rapidly and efficiently", through a register or an alternative mechanism. Countries may make it public. They don't have to.

Here is what a typical entry holds, and the part most registers hide from anyone outside the authorities:

Beneficial owner record: Example Holdings Ltd

Full name
A. N. Example
Nationality
Portuguese
Date of birth
03 / 1984 14
Country of residence
Portugal
Home address
Rua de Exemplo 10, Lisboa
ID or passport no.
P1234567
Nature of interest
Owns 100% through a BVI holding company
Date became owner
2026-11-13
An invented example. Blacked-out fields are what EU legitimate interest applicants, and the UK public, don't see: day of birth, home address and ID number. Authorities and, in most places, banks see everything.
1
Key takeaway

Every serious jurisdiction keeps the owner's name for the authorities. What varies is whether anyone else may look.

Chapter 2

Who counts as a beneficial owner: the 25% and control tests

25%

Most registers test in the same order, the order FATF and the EU use:

  1. Ownership. Anyone holding more than 25% of the shares or votes, directly or through other companies. The EU AML Regulation moves this to "25% or more" from 10 July 2027.
  2. Control by other means. Anyone who can appoint or remove most directors, or who exercises "significant influence or control", whatever they hold. This catches the person behind a nominee shareholder: the UK and Hong Kong rules count a nominee's shares as the nominator's.
  3. Senior managing official. If nobody passes either test, the register records the top manager instead, so the entry is never blank.

The ownership test looks through holding companies. Multiply the percentages down the chain to find your share in the company at the bottom. Try your own structure:

Look-through calculator

You own part of a holding company, which owns part of the operating company. Which registers would name you?

60%
50%
0%

Arithmetic only. Many laws count you as owning everything a company holds once you control it (more than 50% in the UK PSC rules), and any control right beyond shares can name you at 0%. Check the rule in the table for your country.

2
Key takeaway

Holding companies don't reset the count. Multiply down the chain, and remember that control can name you without any shares at all.

Chapter 3

UBO registers by country: 28 compared

Every jurisdiction Heirson forms companies in, plus the UK and the US federal rule. Click a column heading to sort, or filter by who can see the register. Each row links to the law or the registry it comes from, and to our page for that country.

Where you live: pick a country
Who can see it
Beneficial ownership registers by jurisdiction, as at 13 November 2026
Register and who keeps it Source
United KingdomPSC register, filed at Companies HouseMore than 25%, or controlPublicName, nationality, month and year of birth, service address, nature of controlCompanies House within 14 days of a changeNew PSCs verify identity within 14 daysGOV.UK PSC guidance
GibraltarRegister of Ultimate Beneficial OwnersMore than 25%PublicName, month and year of birth, nationality, residence, nature of interest; re-enacted 14 July 202630 days from incorporation2017 Regulations, r.8 and r.26
BVIFiled with the Registrar by the registered agent, since 2 January 202510% for filingLegitimate interest searches show 25%+ owners onlyLegitimate interestSince 1 April 2026, US$75 per search: AML investigations, criminal proceedings, obliged entity due diligence30 days from incorporation; changes within 30 daysBVI Business Companies Act, s.96A, BVI FSC
Cayman IslandsCentral platform, filed through the company's corporate services provider25% or more, or controlLegitimate interestSince 28 February 2025: journalists, researchers, counterparties; search by company name onlyChanges confirmed within 30 days; monthly filing cycleBOT Act (2026 Revision)
BermudaKept by the company and filed with the Registrar through a licensed provider25%Legitimate interestBanks see the full entry; legitimate interest applicants four fields, from September 202630 daysBeneficial Ownership Act 2025
MaltaRegister of Beneficial Owners at the Malta Business RegistryMore than 25%, or controlLegitimate interestFrom 10 July 2025: name, month and year of birth, residence, nationality, interest; answer in 12 working daysNot stated in our sourcesS.L. 386.19, reg. 5 and 7
BulgariaBeneficial owner entry in the Commercial RegisterNot stated in our sourcesLegitimate interestBy law since 2025 (ДВ бр. 49/2025); practice reported to be unevenWith the registrationSeparate filing only if owners are not already the listed shareholdersMeasures against Money Laundering Act, art. 63 and 63b
CyprusUBO register at the Registrar of Companies25% plus one share, or controlBanks and authoritiesPublic access suspended after the 2022 ruling; obliged entities pay EUR 3.5090 days from incorporationConfirmed every year, 1 October to 31 DecemberRegistrar UBO FAQ
EstoniaBeneficial owner data in the e-Business RegisterNot stated in our sourcesBanks and authoritiesFrom 10 July 2026 removed from open data; approved partners via an API with e-ID loginNot stated in our sourcesRIK notice, 4 June 2026
SwitzerlandFederal Transparency Register, from 1 October 2026Not stated in our sourcesBanks and authorities"Nicht öffentlich zugänglich"; banks and AML intermediaries can consult it; registration freeChanges reported on an ongoing basisFederal Office of Justice FAQ
Isle of ManBeneficial Ownership Database, filed by the nominated officer25% or more, then control, then senior managerBanks and authoritiesObliged entities since 31 December 2024; legitimate interest only consulted on (May 2026)21 daysIsle of Man Government
JerseyCentral register at the JFSC Registry25% or more, lower where risk is higherBanks and authoritiesObliged Entity BO register for due diligence; legitimate interest consulted onChanges within 21 daysJFSC guidance
GuernseyFiled with the Registry by the resident agentMore than 25%, or controlAuthoritiesNot public; legitimate interest access proposed (consultation closed 10 April 2026)14 daysGuernsey Registry
PanamaPrivate single register of final beneficiaries, filed by the resident agent (Law 129 of 2020)25%AuthoritiesNot public; the agent and two officials who serve the authorities15 business days from formationChanges: company tells agent in 15 business days, agent updates in 5Law 129 of 2020, arts. 11 and 12
SeychellesKept by the registered agent and uploaded to the FIU's central database10% or more, or controlAuthoritiesThe authorities listed in the Act14 days after creating the register or any changeBO (Amendment) Regulations 2025
BahamasRegistered agents' databases, linked through a secure search system10%AuthoritiesNot open to banks or private firms; no legitimate interest route foundChanges to the agent within 15 daysRegister of Beneficial Ownership Act 2018
BelizeFiled with the Registrar since 202310% or moreFrom a summary of the AML ActAuthoritiesThe agent and the authorities; not open to the publicNot stated in our sourcesBCCAR legislation
UAE mainland and free zonesReal beneficiary register under Cabinet Decision 109 of 2023, kept with the licensing authority25% or more, or controlAuthoritiesCovers companies "including those in commercial free zones"Changes within 15 daysMinistry of Economy
RAK ICCKept by the certified registered agent (BO Regulations 2019)25%, or controlAuthoritiesRAK ICC and competent authorities15 daysFrom summaries of the RegulationsRAK ICC BO Regulations 2019
LabuanFiled with the Registrar by the Labuan trust company25%AuthoritiesLabuan FSA, the owner and people the owner authorises30 days from incorporation and each changePlus a yearly filing by 31 JanuaryLabuan FSA BO Guidelines
MauritiusFiled with the Registrar of CompaniesNot stated in our sourcesAuthoritiesFinancial crimes, police and FSC access, per summaries14 days from the share register entryCBRD statutory obligations
CuraçaoClosed central UBO register at the Chamber of Commerce, since June 2024Not stated in our sourcesAuthoritiesDesignated authorities; each owner can see their own entryNotary files within two weeks of the deedLandsbesluit UBO-registratie
Hong KongSignificant Controllers Register, kept by the company in Hong Kong; not filedMore than 25%, or controlAuthoritiesOpen to law enforcement officers on demandKept up to date; nothing to fileNeeds a Hong Kong designated representativeCompanies Registry SCR FAQ
BahrainUltimate beneficial owner record with the Ministry of Industry and Commerce10% or more, or controlAuthoritiesShareholders themselves are public on SijilatUpdate "immediately", confirm yearlyMinisterial Order 83 of 2020
Nevis LLCNo central register. Registered agents hold owner records under the AML RegulationsAgent's due diligenceNo central registerAuthorities on request; no public accessRegister copies at the agent updated within 15 daysNevis FSRC
Marshall IslandsNo central register. The entity keeps its own record and attests yearlyMore than 25%, then controlNo central registerProduced to the registrar's agent on demand60 days to produce it when askedIRI corporate FAQs
GeorgiaNo beneficial ownership register foundNot applicableNo central registerOwners and directors are public in the company registry anywayNot applicableLaw of Georgia on Entrepreneurs
United States (FinCEN)FinCEN BOI database. US-formed companies exempt since March 202525% or more, or substantial controlNone for US LLCsForeign companies registered in a state: FinCEN and authoritiesForeign companies: 30 calendar days after registeringWyoming, Delaware, New Mexico, Florida and Nevada LLCs: noneFinCEN BOI

Showing all 28 registers. Rows marked "from summaries" rest on a law firm or provider summary of the law; the rest on the law, the regulator or the registry. As at 13 November 2026.

3
Key takeaway

Privacy today is about access, not existence. Pick a register by who can open it, and expect your bank to see it either way.

Chapter 4

The EU UBO register after the 2022 court ruling

From 2020 the EU required every member state to open its register to "any member of the general public". On 22 November 2022 the Court of Justice struck that rule down in WM and Sovim (C-37/20 and C-601/20), holding that open access was a serious interference with the rights to privacy and data protection. Luxembourg, the Netherlands, Austria, Ireland, Cyprus and Malta were among the states reported to have closed or limited their registers soon after.

The EU then rebuilt access around a legitimate interest test in the sixth AML Directive, Directive (EU) 2024/1640, and moved the rules on who is an owner into a directly applicable AML Regulation (EU) 2024/1624:

  • 22 November 2022Public access "in all cases" declared invalid. Registers close or restrict.
  • 10 July 2025National law must give access to anyone who can show a legitimate interest: at least name, month and year of birth, country of residence, nationality and nature and extent of the interest (Art. 74).
  • 10 July 2026Full access rules due (Arts. 11, 12, 13 and 15): authorities get immediate, free, unfiltered access without alerting the company; banks get timely access during due diligence.
  • 25 September 2026The Commission sends formal notices to 18 member states for incomplete transposition, as reported in the specialist press.
  • 10 November 2026Registers must answer a legitimate interest request within 12 working days, extendable in surges.
  • 10 July 2027The AML Regulation applies: ownership threshold "25% or more", changes reported within 28 calendar days, and the rest of the Directive in force.

Who has a legitimate interest?

The Directive presumes one for journalists and civil society working on money laundering, academics, anyone likely to do a deal with the company, banks outside the EU doing due diligence, and several public bodies. Others can apply case by case. The company is not told who looked, but the register logs access, and an owner can ask for the occupation of a journalist or NGO that searched. Owners at real risk of fraud, kidnapping, violence or harassment can ask for an exemption (Art. 15).

4
Key takeaway

EU registers are closed to the curious, open to anyone with a reason. Expect a counterparty or reporter to be able to find you.

Chapter 5

UK PSC, US FinCEN and the offshore registers

United Kingdom: still public, now with ID checks

The UK left the EU before the ruling and kept its persons with significant control register open. Anyone can see a PSC's name, nationality, month and year of birth, service address and nature of control. A PSC is anyone with more than 25% of shares or votes, the right to appoint or remove most directors, or significant influence or control. Since 18 November 2025, PSCs must also verify their identity with Companies House; a new PSC does it within 14 days of being added. See our UK limited company page.

United States: the federal register shrank

The Corporate Transparency Act started BOI reporting in 2024. An interim rule of 26 March 2025, made final from 14 August 2026, exempted every company formed in the US and every US person. Today only foreign companies registered to do business in a state file, within 30 calendar days. A Wyoming or New Mexico LLC owned from abroad files nothing with FinCEN, but its owner still appears on the EIN application and on Form 5472 each year, and every US bank still identifies owners.

Offshore centres: registers built for the authorities

The classic offshore centres all keep owner data, almost always away from the public. The BVI moved filing to the Registrar on 2 January 2025 and opened paid legitimate interest searches on 1 April 2026. Cayman opened legitimate interest access on 28 February 2025, searchable only by company name. Panama, the Bahamas, Seychelles and Belize keep registers for the authorities alone. Hong Kong asks the company to keep its own register in the city for officers to inspect. Nevis and the Marshall Islands have no central register at all: the agent or the company holds the record and hands it over when asked.

None of this makes an owner invisible. It decides who can find you without a court order. Our guide to anonymous companies sets out what privacy is still legal, and the nominee director guide explains why nominees don't change the register entry.

5
Key takeaway

The UK is public, the US federal register skips US-formed LLCs, and offshore registers serve the authorities. Your bank sees you in all three.

Chapter 6

Who sees what: from the public to your tax office

Think of owner data as a ladder. Each rung up sees more, and the top rung sees you wherever the company is formed:

1
The publicSearch the register online, no reason needed
UK, Gibraltar
2
Legitimate interest applicantsJournalists, NGOs, counterparties: limited fields, after a check
EU, BVI, Cayman, Bermuda, Malta
3
Your bank or payment providerMust identify you under FATF Recommendation 10 before opening an account
Everywhere
4
Registry, agent and regulatorsThe full entry, with ID number and home address
Everywhere
5
Your tax officeReceives your bank account data as a controlling person under the CRS, or FATCA for US links
Where you live

The CRS and its list of participating countries explain rung five. It is the one that matters for tax, and it doesn't depend on any register being public.

6
Key takeaway

Choosing a private register keeps you off the internet. It never keeps you from your bank or your own tax office.

Chapter 7

UBO filing deadlines and late fines

Your registered agent usually files the first entry as part of formation. The duty that catches owners out is the change: a share sale, a new partner, a trust taking over the shares. Tell your agent the same week. These are the published fines for missing it:

US$500BVI: a month for a late filing, rising; changes up to US$6,000Business Companies Act, Sch. 1
GBP 100Jersey: a month after 21 days, capped at GBP 600, and possible strike offJFSC fees and penalties
B/.50,000Panama: top of the agent's fine per company, plus B/.500 a dayLaw 129 of 2020
BD 1,000Bahrain: a day, capped at BD 50,000; suspension or strike offMinisterial Order 83 of 2020
SCR 150,000Seychelles: maximum penalty for upload failuresBeneficial Ownership Act
EUR 5,000Cyprus: maximum fine for late filing or confirmationRegistrar of Companies
7
Key takeaway

Ownership changes trigger the deadline, not the calendar. Tell your agent within a week and the fines never start.

Chapter 8

UBO register questions, answered

?!
What does UBO stand for?
Ultimate beneficial owner: the natural person who in the end owns or controls a company, directly or through other companies, trusts or nominees.
Is the UBO register public?
Only in a few places. Of the 28 registers on this page, the UK and Gibraltar are open to anyone. EU states, the BVI, Cayman, Bermuda and Malta give access to people with a legitimate interest. The rest are for banks or the authorities only.
How do I find the UBO of a company?
Search the public register where one exists (UK, Gibraltar). In the EU, apply for legitimate interest access. Elsewhere, ask the company: a certificate of incumbency from its registered agent and a signed ownership chart are the usual route. Our country company search pages show what each registry reveals.
Does a nominee shareholder change the UBO entry?
No. The nominee is the legal owner on the share register, but the register of beneficial owners names you. FATF's definitions say a nominee "is never the beneficial owner". See the nominee shareholder guide.
Does a US LLC have to report its owners in 2026?
Not to FinCEN, if it was formed in the US. Since March 2025 only foreign companies registered in a state report. The IRS still gets the owner on the EIN application and on Form 5472 for a foreign-owned single-member LLC.
Who files the UBO information?
Usually the registered agent or company secretary, using details you give them at formation. In Panama, the BVI, Seychelles, Labuan and Cayman the agent or service provider does it; in Hong Kong the company keeps its own register; in the UK the company files with Companies House.
Is there a UBO threshold lower than 25%?
Yes. The BVI files at 10%, and Seychelles, the Bahamas, Belize and Bahrain use 10%. The EU may lower its threshold for higher risk sectors under the AML Regulation.
Cite this guideHeirson (2026). "UBO registers by country: who can see the owner of your company." https://heirson.com/ubo-register/ (updated 13 November 2026).

Changelog

  • 13 November 2026: first published, with 28 registers from the laws, regulators and registries linked in the table, Directive (EU) 2024/1640, the CJEU judgment of 22 November 2022 and FinCEN's BOI rule as final from 14 August 2026.
Filed right, kept private where the law allows

We file your owner details. You choose how public they are.

Every company we form has its beneficial owner filing done by the registered agent, on time. Pick a place by who can see the register.