The rules for access to information about beneficial owners in the European economic area before and after the CJEU judgement
| Country | Access to NCR before the CJEU judgement | Access to NCR one year after CJEU judgement |
|---|---|---|
| Austria | Open public access after payment of a fee | Access only for entities with legitimate interest – journalists, scientists and representatives of civil society working on anti-money laundering-related issues |
| Belgium | Authentication was required to access | Access only for entities with legitimate interest – persons engaged in the fight against money laundering and its predicate offences |
| Bulgaria | Open public BOR without additional charge or authentication | Registration requirement introduced without additional fee or authentication |
| Croatia | Authentication was required to access | No change in access to the country’s BOR |
| Cyprus | Open public access after payment of a fee | Access to BOR suspended from November 2022; lack of access, even when entities demonstrate legitimate interest |
| Czech Republic | Open public BOR without additional charge or authentication | No change in access to the country’s BOR |
| Denmark | Open public BOR without additional charge or authentication | No change in access to the country’s BOR |
| Estonia | Authentication and payment of a fee were required | No change in access to the country’s BOR |
| Finland | Access only for entities with legitimate interest after payment of a fee | Access only for entities with legitimate interest – media and others whose purpose for using the data complies with the national act on money laundering |
| France | Authentication was required to access | No change in access to the country’s BOR |
| Germany | Authentication and payment of a fee were required | Access only for entities with legitimate interest – journalists and civil society organisations must first register to use the BORs, and their legitimate interest is then assessed. After receiving a username and password, they should demonstrate legitimate interest for each request |
| Greece | Authentication and payment of a fee were required | Access only for entities with legitimate interest; entities must demonstrate legitimate interest |
| Hungary | Registration and payment of a fee were required | No change in access to the country’s BOR |
| Iceland | The BOR has been operational since 2019, with access restricted to competent authorities such as regulatory bodies, reporting entities and tax authorities | No change in access to the country’s BOR |
| Ireland | Authentication and payment of a fee were required | Access only for entities with legitimate interest – persons engaged in the fight against money laundering and its predicate offences |
| Italy | Lack of BOR; BOR became operational from 9 October 2023 | Access only for entities with legitimate interest – detailed information provided by provincial chambers of commerce |
| Latvia | Open public BOR to current data without additional charge or authorisation; with authentication, the user also has access to historical data | No change in access to the country’s BOR |
| Liechtenstein | Access to BO data required a written application; only competent domestic authorities could access BO data without limitation via a retrieval procedure; for other entities, registration and payment were required | No change in access to the country’s BOR |
| Lithuania | Authentication and payment of a fee were required | Access only for entities with legitimate interest – a reason for accessing the data must be provided |
| Luxembourg | Authentication was required | Access only for entities with legitimate interest – those entitled to receive data in cases defined by law, including professionals from the financial and insurance sectors, auditors, real estate agents and developers, persons carrying out a family office activity, notaries and lawyers |
| Malta | Authentication and payment of a fee were required | Access suspended from November 2022 |
| The Netherlands | Authentication and payment of a fee were required | Access suspended from November 2022; according to a Dutch Government’s statement, it will only be re-opened to competent authorities, institutions and members with a legitimate interest |
| Norway | Access only for entities with legitimate interest – public authorities, media, civil society organisations, higher education institutions | BOR became operational after the CJEU judgement, on 1 October 2024; mandatory registration requirements are to take effect from 31 July 2025 |
| Poland | Open public BOR without additional charge or authentication | No change in access to the country’s BOR |
| Portugal | Authentication was required to access | No change in access to the country’s BOR |
| Romania | Registration and payment of a fee were required | Access limited to entities with legitimate interest – for authorities/institutions with supervisory/control powers and reporting entities when applying Know Your Customer measures |
| Slovakia | Open public BOR without additional charge or authentication | No change in access to the country’s BOR |
| Slovenia | Registration and payment of a fee were required (in some cases, without registration, with so-called “anonymous access/search”) | No change in access to the country’s BOR |
| Spain | Lack of public BOR; access only for VIP institutions (public authorities, notaries, and registrars); required authentication and authorisation | Access only for entities with legitimate interest – those that can prove a connection to anti-money laundering and terrorism financing to the registry authority |
| Sweden | Open public BOR without additional charge or authentication; users must only confirm that they have read the terms and conditions | Partially limited open access – users that have authenticated themselves electronically must contact the Swedish Companies Registration Office via e-mail or telephone |
| UK | Open public access without additional charge, registration or authentication | Starting from 27 January 2025, individuals may apply to have personal information – such as residential addresses and signatures – suppressed from historical documents |
| Country | Access to | Access to |
|---|---|---|
| Austria | Open public access after payment of a fee | Access only for entities with legitimate interest – journalists, scientists and representatives of civil society working on anti-money laundering-related issues |
| Belgium | Authentication was required to access | Access only for entities with legitimate interest – persons engaged in the fight against money laundering and its predicate offences |
| Bulgaria | Open public | Registration requirement introduced without additional fee or authentication |
| Croatia | Authentication was required to access | No change in access to the country’s |
| Cyprus | Open public access after payment of a fee | Access to |
| Czech Republic | Open public | No change in access to the country’s |
| Denmark | Open public | No change in access to the country’s |
| Estonia | Authentication and payment of a fee were required | No change in access to the country’s |
| Finland | Access only for entities with legitimate interest after payment of a fee | Access only for entities with legitimate interest – media and others whose purpose for using the data complies with the national act on money laundering |
| France | Authentication was required to access | No change in access to the country’s |
| Germany | Authentication and payment of a fee were required | Access only for entities with legitimate interest – journalists and civil society organisations must first register to use the BORs, and their legitimate interest is then assessed. After receiving a username and password, they should demonstrate legitimate interest for each request |
| Greece | Authentication and payment of a fee were required | Access only for entities with legitimate interest; entities must demonstrate legitimate interest |
| Hungary | Registration and payment of a fee were required | No change in access to the country’s |
| Iceland | The | No change in access to the country’s |
| Ireland | Authentication and payment of a fee were required | Access only for entities with legitimate interest – persons engaged in the fight against money laundering and its predicate offences |
| Italy | Lack of BOR; | Access only for entities with legitimate interest – detailed information provided by provincial chambers of commerce |
| Latvia | Open public | No change in access to the country’s |
| Liechtenstein | Access to | No change in access to the country’s |
| Lithuania | Authentication and payment of a fee were required | Access only for entities with legitimate interest – a reason for accessing the data must be provided |
| Luxembourg | Authentication was required | Access only for entities with legitimate interest – those entitled to receive data in cases defined by law, including professionals from the financial and insurance sectors, auditors, real estate agents and developers, persons carrying out a family office activity, notaries and lawyers |
| Malta | Authentication and payment of a fee were required | Access suspended from November 2022 |
| The Netherlands | Authentication and payment of a fee were required | Access suspended from November 2022; according to a Dutch Government’s statement, it will only be re-opened to competent authorities, institutions and members with a legitimate interest |
| Norway | Access only for entities with legitimate interest – public authorities, media, civil society organisations, higher education institutions | |
| Poland | Open public | No change in access to the country’s |
| Portugal | Authentication was required to access | No change in access to the country’s |
| Romania | Registration and payment of a fee were required | Access limited to entities with legitimate interest – for authorities/institutions with supervisory/control powers and reporting entities when applying Know Your Customer measures |
| Slovakia | Open public | No change in access to the country’s |
| Slovenia | Registration and payment of a fee were required (in some cases, without registration, with so-called “anonymous access/search”) | No change in access to the country’s |
| Spain | Lack of public BOR; access only for | Access only for entities with legitimate interest – those that can prove a connection to anti-money laundering and terrorism financing to the registry authority |
| Sweden | Open public | Partially limited open access – users that have authenticated themselves electronically must contact the Swedish Companies Registration Office via e-mail or telephone |
| Open public access without additional charge, registration or authentication | Starting from 27 January 2025, individuals may apply to have personal information – such as residential addresses and signatures – suppressed from historical documents |
The table includes current European Union Member States, as well as Iceland, Liechtenstein and Norway – countries of the European Economic Area – because their legislation aligns with EU standards, particularly in areas related to financial regulation and anti-money laundering efforts. The table also includes information on the UK, as Brexit occurred between the adoption of the 5AMLD and the 6AMLD
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