Table 1.

The rules for access to information about beneficial owners in the European economic area before and after the CJEU judgement

CountryAccess to NCR before the CJEU judgementAccess to NCR one year after CJEU judgement
AustriaOpen public access after payment of a feeAccess only for entities with legitimate interest – journalists, scientists and representatives of civil society working on anti-money laundering-related issues
BelgiumAuthentication was required to accessAccess only for entities with legitimate interest – persons engaged in the fight against money laundering and its predicate offences
BulgariaOpen public BOR without additional charge or authenticationRegistration requirement introduced without additional fee or authentication
CroatiaAuthentication was required to accessNo change in access to the country’s BOR
CyprusOpen public access after payment of a feeAccess to BOR suspended from November 2022; lack of access, even when entities demonstrate legitimate interest
Czech RepublicOpen public BOR without additional charge or authenticationNo change in access to the country’s BOR
DenmarkOpen public BOR without additional charge or authenticationNo change in access to the country’s BOR
EstoniaAuthentication and payment of a fee were requiredNo change in access to the country’s BOR
FinlandAccess only for entities with legitimate interest after payment of a feeAccess only for entities with legitimate interest – media and others whose purpose for using the data complies with the national act on money laundering
FranceAuthentication was required to accessNo change in access to the country’s BOR
GermanyAuthentication and payment of a fee were requiredAccess 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
GreeceAuthentication and payment of a fee were requiredAccess only for entities with legitimate interest; entities must demonstrate legitimate interest
HungaryRegistration and payment of a fee were requiredNo change in access to the country’s BOR
IcelandThe BOR has been operational since 2019, with access restricted to competent authorities such as regulatory bodies, reporting entities and tax authoritiesNo change in access to the country’s BOR
IrelandAuthentication and payment of a fee were requiredAccess only for entities with legitimate interest – persons engaged in the fight against money laundering and its predicate offences
ItalyLack of BOR; BOR became operational from 9 October 2023Access only for entities with legitimate interest – detailed information provided by provincial chambers of commerce
LatviaOpen public BOR to current data without additional charge or authorisation; with authentication, the user also has access to historical dataNo change in access to the country’s BOR
LiechtensteinAccess 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 requiredNo change in access to the country’s BOR
LithuaniaAuthentication and payment of a fee were requiredAccess only for entities with legitimate interest – a reason for accessing the data must be provided
LuxembourgAuthentication was requiredAccess 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
MaltaAuthentication and payment of a fee were requiredAccess suspended from November 2022
The NetherlandsAuthentication and payment of a fee were requiredAccess 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
NorwayAccess only for entities with legitimate interest – public authorities, media, civil society organisations, higher education institutionsBOR became operational after the CJEU judgement, on 1 October 2024; mandatory registration requirements are to take effect from 31 July 2025
PolandOpen public BOR without additional charge or authenticationNo change in access to the country’s BOR
PortugalAuthentication was required to accessNo change in access to the country’s BOR
RomaniaRegistration and payment of a fee were requiredAccess limited to entities with legitimate interest – for authorities/institutions with supervisory/control powers and reporting entities when applying Know Your Customer measures
SlovakiaOpen public BOR without additional charge or authenticationNo change in access to the country’s BOR
SloveniaRegistration 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
SpainLack of public BOR; access only for VIP institutions (public authorities, notaries, and registrars); required authentication and authorisationAccess only for entities with legitimate interest – those that can prove a connection to anti-money laundering and terrorism financing to the registry authority
SwedenOpen public BOR without additional charge or authentication; users must only confirm that they have read the terms and conditionsPartially limited open access – users that have authenticated themselves electronically must contact the Swedish Companies Registration Office via e-mail or telephone
UKOpen public access without additional charge, registration or authenticationStarting from 27 January 2025, individuals may apply to have personal information – such as residential addresses and signatures – suppressed from historical documents
Note(s):

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

Source(s): Authors’ own work; Study based mainly on data submitted by Member States and available on the European e-Justice Portal

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