On 22 November 2022, the CJEU struck down unrestricted public access to UBO data in the EU beneficial ownership register framework, citing privacy and data protection concerns.
The ruling did not abolish EU beneficial ownership registers or UBO reporting. Authorities and regulated businesses can still access ownership data for enforcement and due diligence, including through applicable UBO register access EU procedures. It targeted unrestricted public access, not transparency itself.
The EU is shifting to controlled access, stronger register verification and clearer UBO rules. Reliable beneficial ownership data remains vital for KYB, financial-crime detection and sanctions screening.
This guide explains the cjeu ubo ruling’s impact, who can access UBO data, how legitimate interest works, and what it means for KYB and AML compliance.
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What Was the 2022 CJEU Beneficial Ownership Ruling?
On 22 November 2022, the CJEU ruled in Joined Cases C-37/20 and C-601/20 that unrestricted public access to beneficial ownership information in the EU beneficial ownership register framework violated privacy and data-protection rights under Articles 7 and 8 of the EU Charter.
Which EU Rule Did the CJEU Invalidate?
The Court invalidated the Fifth Anti-Money Laundering Directive's requirement that anyone could access specified UBO data without demonstrating a legitimate interest. It did not abolish beneficial ownership registers or reporting obligations. Companies still had to identify and report UBOs, while authorities and regulated businesses retained access for AML, KYC and KYB purposes. The cjeu ubo ruling therefore changed the conditions for public disclosure rather than eliminating UBO register access EU-wide.
Why Did the CJEU Strike Down Unrestricted Public Access?
The CJEU found that unrestricted access to personal UBO information disproportionately interfered with privacy and data-protection rights. It did not reject beneficial ownership registers or their AML purpose. Instead, it ruled that public access must be proportionate, purpose-based and subject to stronger safeguards.
Privacy and Personal Data Were at the Centre of the Case - The Court relied on Articles 7 and 8 of the EU Charter of Fundamental Rights, protecting private life and personal data. An EU beneficial ownership register can reveal a person's ownership interests, financial position and links to companies. Public disclosure also allows information to be copied, indexed and redistributed indefinitely.
The Court Did Not Reject AML Transparency as a Legitimate Goal - The CJEU recognised that combating money laundering, terrorist financing and corporate misuse is a legitimate public-interest objective. However, it found that allowing anyone to access UBO data without a relevant reason went further than necessary. Access therefore remains available to authorities and obliged entities, while broader access is increasingly based on legitimate interest and structured UBO register access EU rules.
What Changed for EU Beneficial Ownership Registers After the Ruling?
The cjeu ubo ruling changed how EU beneficial ownership registers can be accessed, particularly by the general public.
UBO reporting obligations remained in place, while access shifted toward competent authorities, AML-regulated businesses and users with a legitimate interest. For businesses conducting KYB, the EU beneficial ownership register remains an important source of ownership information, but it should be used alongside other verification and screening data.
Area | Before the 2022 Ruling under 5AMLD | Post-CJEU Direction |
General public | Broad access without demonstrating a specific interest | Universal access requirement invalidated |
Competent authorities | Extensive access | Access preserved and strengthened |
AML obliged entities | Access for CDD purposes | Access preserved |
Journalists | Could use public-access regime | Certain users expressly recognised as having legitimate interest |
NGOs / civil society | Could use public-access regime | Certain organisations expressly recognised as having legitimate interest |
Other individuals/businesses | Broad public access | May need to demonstrate legitimate interest |
Privacy safeguards | Limited exceptions existed | Greater emphasis on proportionality, identification and access controls |
UBO reporting | Required | Still required |
Central registers | Required | Still required and strengthened |
The judgment affected the legal basis for universal public access, but it did not remove the EU beneficial ownership register system. National register systems, access procedures and legislative responses did not all change in exactly the same way or at the same speed.
As a result, practical UBO register access EU procedures may vary between Member States while remaining shaped by the principles established in the cjeu ubo ruling.
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How to Verify an EU Company's Beneficial Owners After the CJEU Ruling
Verifying an EU company's beneficial owners now requires understanding register access rules, tracing ownership structures and using reliable KYC, KYB and AML data. The EU beneficial ownership register can support this process, provided teams understand the applicable UBO register access in the EU rules.
The CJEU ruling restricted unrestricted public access, but businesses and obliged entities can still conduct beneficial ownership checks through permitted register access, legitimate-interest procedures and supporting corporate records. The CJEU UBO ruling therefore changes the access route rather than removing the underlying verification obligation.
Step 1: Confirm the company's identity
Verify the legal name, registration number, jurisdiction and current company status before beginning the ownership review. This prevents confusion between similarly named entities and ensures you are checking the correct company in the relevant EU beneficial ownership register.
Confirm that the company is active, registered and operating under the expected legal form. Record the search date and source so your KYB and AML compliance file contains a clear audit trail.
Step 2: Identify the relevant national register
Determine which Member State's company and beneficial ownership registers apply to the entity. EU beneficial ownership registers are operated nationally, while systems such as BORIS support cross-border interconnection.
Check the company's registered office, incorporation jurisdiction and any relevant branch registrations. Do not assume that one EU UBO register or UBO register access procedure in the EU applies identically across all Member States.
Step 3: Establish your access basis
Confirm whether you are accessing the information as a competent authority, AML obliged entity, journalist, civil society organisation, prospective counterparty or another legitimate-interest applicant. Your status may determine what beneficial ownership information you can access and how you must verify your identity.
For regulated businesses, document that the search supports customer due diligence, KYB verification or another AML/CFT purpose. Other applicants may need to demonstrate a legitimate interest connected with preventing or combating money laundering, predicate offences or terrorist financing. This purpose-based approach reflects the reasoning behind the CJEU UBO ruling and the developing framework for UBO register access in the EU.
Step 4: Retrieve available ownership information
Collect the company's registered beneficial ownership details, shareholder information, directors, ownership percentages and any available control information. Review every ownership layer rather than stopping at the first corporate shareholder.
Use the available EU UBO register data alongside company filings, customer-provided documents and reliable independent sources. Compare the information for discrepancies, identify the natural persons who ultimately own or control the company, and record the evidence supporting your beneficial ownership assessment.
Step 5: Map the complete ownership chain
Trace ownership through every intermediate company, holding structure, trust or nominee arrangement until you identify the natural persons who ultimately own or control the business. This supports accurate UBO identification and helps compliance teams understand indirect ownership across complex corporate structures.
Document each ownership layer, control relationship and ownership percentage. A complete ownership map helps reveal hidden beneficial owners, nominee arrangements and control through other means, supporting stronger KYB and AML compliance regardless of the applicable UBO register access in the EU process.
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Step 6: Cross-check the information
Compare beneficial ownership register data with company filings, shareholder records, customer-provided documents and other reliable independent sources. Cross-checking can reveal outdated records, undisclosed ownership interests and discrepancies requiring enhanced due diligence.
Do not rely on a single EU beneficial ownership register or UBO database. Validate key details across independent sources and investigate inconsistencies before completing customer due diligence or approving a business relationship. The CJEU UBO ruling reinforces the importance of controlled access, but it does not make register information conclusive on its own.
Step 7: Screen the relevant individuals and entities
Screen beneficial owners, directors, shareholders and connected entities against sanctions lists, PEP databases, watchlists and adverse media sources. Screening helps identify potential money laundering, corruption, terrorist financing, sanctions and reputational risks.
Apply risk-based AML screening to both natural persons and legal entities. Where results indicate elevated risk, conduct enhanced due diligence, verify the information manually and document how the findings affected the KYB assessment.
Step 8: Document findings and monitor for changes
Record the sources reviewed, ownership calculations, control relationships, discrepancies, risk assessment and decisions made. Clear documentation creates an auditable record of UBO identification, beneficial ownership verification and AML compliance.
Continue monitoring for ownership changes, new control relationships, sanctions exposure and emerging financial crime risks. Ongoing KYB monitoring helps keep beneficial ownership records accurate, current and aligned with EU AML requirements, including future developments affecting the EU beneficial ownership register and UBO register access in the EU.
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- Retrieve official company and registry information
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- Identify the natural persons who ultimately own or control the company
- Screen companies, directors, shareholders and UBOs for AML risk
- Maintain an auditable record of the compliance process
Is There One EU Beneficial Ownership Register?
No. Each EU Member State operates its own central beneficial ownership register. These national systems are connected through the Beneficial Ownership Registers Interconnection System (BORIS), which supports cross-border access for authorised users searching for information through the eu beneficial ownership register framework.
BORIS is not an unrestricted public database. Access depends on the user's status, purpose and legal basis. Authorities generally have the broadest access, obliged entities can use register data for due diligence, and other applicants may need to demonstrate a legitimate interest. These rules are central to understanding ubo register access eu requirements.
How Did the EU Respond to the CJEU Ruling?
The EU did not abandon beneficial ownership registers. Its 2024 AML/CFT package replaced unrestricted public access with a purpose-based model following the cjeu ubo ruling:
- Authorities receive broad access.
- Regulated businesses can access UBO data for due diligence.
- Journalists, civil society organisations and certain businesses may access information by demonstrating legitimate interest.
The new framework preserves UBO transparency while adding stronger privacy, identity-verification and register-accuracy safeguards. As a result, the eu beneficial ownership register system continues to support AML enforcement, but access is now more carefully controlled.
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Who Can Access EU Beneficial Ownership Registers Under the New Rules?
The post-CJEU framework uses tiered access based on the user's role and purpose. Competent authorities receive broad access, while AML-regulated businesses can consult UBO data for customer due diligence. Journalists, civil society organisations and certain prospective counterparties may also access information by demonstrating a legitimate AML-related interest. This tiered approach is the foundation of current ubo register access eu rules and reflects the privacy concerns raised by the cjeu ubo ruling.
Competent Authorities - Directive (EU) 2024/1640 provides competent authorities with immediate, direct, unfiltered and free access to interconnected beneficial ownership registers. Eligible bodies may include financial intelligence units, tax and sanctions authorities, AMLA, EPPO, OLAF, Europol and Eurojust.
AML Obliged Entities - Banks, payment providers, crypto-asset firms, accountants, lawyers and other obliged entities can access UBO information for CDD and KYB checks. The CJEU ruling did not remove this access. However, register data should still be cross-checked against corporate records, customer documents, ownership structures, sanctions, PEP and adverse-media checks. The eu beneficial ownership register should therefore be treated as one part of a broader verification process.
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What Is "Legitimate Interest" for Beneficial Ownership Register Access?
After the CJEU ruling, beneficial ownership access is no longer simply public or private. Legitimate interest provides controlled access for people who need UBO information for genuine AML/CFT purposes, such as investigating money laundering, terrorist financing or corporate misuse. This distinction is one of the most important consequences of the cjeu ubo ruling and helps explain how ubo register access eu operates today.
Who Is Deemed to Have a Legitimate Interest?
Directive (EU) 2024/1640 recognises:
- Journalists and media professionals
- NGOs, civil society organisations and academic researchers
- Businesses preparing to transact with a company
- Certain non-EU regulated entities and authorities
- Public bodies involved in company law, EU funding or procurement
Other applicants may apply case by case by demonstrating a genuine AML/CFT-related interest. Depending on the applicant's status and purpose, this may provide access to relevant information held through the eu beneficial ownership register framework.
How Does the Legitimate-Interest Application Process Work?
Eligible applicants may need to verify their identity, explain their AML/CFT-related purpose and, where relevant, show a connection with the company being investigated. Authorities may also consider the applicant’s occupation or organisational role.
From 10 November 2026, Article 13 generally requires decisions within 12 working days. Approved access may remain valid for three years, with later requests usually processed within seven working days. National procedures may vary. Applicants seeking ubo register access eu should therefore check the relevant Member State's process rather than assuming that every national register operates identically.
Can Beneficial Owners Still Restrict Access to Their Information?
Yes, but only in exceptional cases. Under Directive (EU) 2024/1640, beneficial owners may request restricted access where disclosure creates a disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation. Similar protections may apply to minors and legally incapable people.
Register authorities assess requests individually, balancing privacy and personal-data protection against AML transparency objectives. This reflects the proportionality concerns at the heart of the cjeu ubo ruling while preserving the wider transparency purpose of the eu beneficial ownership register system.
What Does the 2026 Across Fiduciaria Judgment Add?
On 21 May 2026, the CJEU confirmed that legitimate-interest access to beneficial ownership information can comply with EU privacy rights. The judgment distinguishes this proportionate, purpose-based access from the indiscriminate public access rejected in 2022. It also helps clarify the future of UBO register access in the EU and confirms that the CJEU UBO ruling did not eliminate the EU beneficial ownership register framework.
How Are EU Beneficial Ownership Rules Changing Beyond Register Access?
The EU’s 2024 AML package also strengthens UBO data quality. Regulation (EU) 2024/1624 considers both ownership and control, with 25% or more as an important threshold. Companies must keep beneficial ownership information accurate and current, report changes and address discrepancies.
The rules also increase scrutiny of nominee shareholders and directors. Most provisions apply from 10 July 2027. These changes affect how businesses use the EU beneficial ownership register and prepare for future UBO register access in the EU.
What Does the CJEU Ruling Mean for KYC, KYB and AML Compliance?
Restricted public access does not reduce AML obligations. Regulated businesses must still identify and verify UBOs, trace ownership structures, screen relevant parties for sanctions, PEPs and adverse media, and confirm that information is accurate and current. The CJEU UBO ruling changed how certain users access information, but it did not remove the compliance value of the EU beneficial ownership register.
UBO registers are valuable sources, but not conclusive proof. Compliance teams should cross-check registry data, investigate discrepancies, document decisions and monitor ownership changes. Understanding UBO register access in the EU is therefore only one part of a complete KYB and AML process.
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- Identify directors, shareholders and UBOs
- Map complex ownership chains
- Screen individuals and businesses for sanctions, PEPs, watchlists and adverse media
- Monitor customers for AML risk changes
Bottom Line
The CJEU UBO ruling invalidated unrestricted public access to certain beneficial ownership information, not the EU beneficial ownership register or UBO registers themselves. Companies must still identify and report their beneficial owners, while authorities and regulated businesses retain important access rights. The decision therefore changed how UBO register access in the EU is structured rather than ending beneficial ownership transparency.
Directive 2024/1640 and Regulation 2024/1624 create a more structured balance between transparency, AML enforcement and data protection. Access for the wider public is increasingly linked to legitimate interest, while register accuracy and verification requirements are being strengthened. For businesses, understanding the rules around UBO register access EU requirements is now essential when planning KYB and AML processes.
For compliance teams, the practical task remains identifying the natural people behind a company, understanding how they exercise ownership or control, screening them for financial-crime risks and maintaining an auditable record of those checks.
