The Ultimate Guide to Accessing UBO Verification Data (2025)
Before we cover how to access beneficial ownership data, let’s dispel some common misconceptions about the definition of a UBO.
What Is an Ultimate Beneficial Owner?
The FATF states that the ultimate beneficial owner of a legal entity is a human being who ultimately controls or derives the greatest benefit from the legal entity, or the person who exercises “ultimate effective control” over it.
According to industry best practices, this can be broken down into the following:
Financial benefit: 25% of shares in a company.
Voting control: 25% of voting rights
Effective control. Someone with control in practice, not just theory.
Important: definitions vary by jurisdiction.
There Are Different Definitions of Beneficial Ownership
In the UK: The UBO can also be someone who can – directly or indirectly – appoint or remove most of the board of directors.
In certain sectors: Within the EU, some sectors apply a 15% rule for high-risk sectors.
In the EU: While the EU 5AMLD Directive defined the UBO threshold as “more than twenty-five per cent”, as PwC found in its research, Austria, Cyprus, Norway, Malta, and Finland opted for “25 per cent or more” – a subtle difference.
UBO Identification V Verification: What’s the Difference?
You identify the UBO when the customer tells you who they’re UBO is. You verify what they say against the official record.
What Happens If You Can’t Verify the UBO?
If you can’t verify the UBO of a legal entity, you have a fallback option: the senior management official rule.
How it works: The analyst designates a senior official – like a CEO – as what the Dutch call the “pseudo-UBO”.
Risk-sensitive: As the Dutch Wwft states, this should only be used in “risk-relevant” situations.
Legally speaking: This does not count as “UBO verification” but merely acts as a legal last resort.
In short: Only use the senior management official rule in low-risk scenarios as a last resort.
What Information Do You Need to Verify UBOs?
Financial crime investigators use official documentation filed at registries to confirm who owns or controls the legal entity.
Let’s bust another myth about UBO verification: in an age of UBO registries, verification doesn’t mean relying solely on self-reported UBO disclosures at official registries.
Why a Multi-Pronged Approach to UBO Verification Matters
The Financial Action Task Force recommends a “multi-pronged” approach to UBO verification – one that comprises multiple sources of official information.
Start with: Shareholder information from company registries.
Cross-check with: UBO information from UBO registries.
Supplement with: Other information from government databases (land and tax registries, for example).
Why? UBO declarations are generally unverified by the authorities. It’s important to cross-check one source against other official sources.
For example, Kyckr’s automated UBO verification tool, UBO Verify, extracts shareholder data from official registry filings in real time to automatically calculate the UBO.
UBO Disclosures
Accessing UBO Information
UBO disclosures can (in theory) be retrieved from official UBO registers. The problem? Few are easily accessed.
Only to law enforcement: This includes half of all Canadian provincial registers, some Asian countries (such as Singapore and Hong Kong), and secrecy havens like the British Virgin Islands.
Only to local obliged entities: This includes 15% of all European beneficial ownership registers, such as Cyprus and Greece (although this is set to change, in theory, with the passage of the 6AMLD).
Virtually impossible: Transparency International found that 48% of EU UBO registers providing ‘legitimate interest access’ (LIA) were, in practice, virtually impossible to access.
Tip: If it’s too difficult to access UBO filings at a registry, skip the step and map out the corporate ownership chain using shareholder information gleaned from company filings.
What Information Is Provided?
It depends. Even in a supranational body like the European Union, member states differ on what UBO data they record.
Most record the name, nationality, country of residence and “extent of interest”.
No EU states record historic UBO data (which makes tracing ownership difficult).
Some states (like Spain) don’t even record the extent of beneficial ownership.
Can You Receive UBO Data?
Some UBO registers offer APIs but differ on who can access them. While France, the UK and Estonia offer public access, Lithuania, Slovakia and the Netherlands only make it available to local entities.
But UBO disclosures are half the story. As Open Ownership research highlights, UBO registers rely on self-disclosed filings from the companies themselves, with few registers actively verifying that information.
So, what else does a financial crime team need?
Shareholder information
Shareholder information is the next layer to parse. The difficulty is that this is usually a manual process, with investigators having to build a picture of the UBO through various documents.
Accessing Shareholder Information
Many countries provide public shareholder information – even in "tax havens” like the Cayman Islands and Cyprus. But they differ.
Some company registers don’t provide publicly available shareholder information: For example, Belgium, the British Virgin Islands, and most US and Canadian provinces.
Some registers provide it for free: Countries like the UK make shareholder filings instantly accessible via downloads
Some require login: Official Maltese shareholder data can only be retrieved after logging in and authenticating your identity.
Some information must be physically retrieved and photocopied: Cypriot shareholder registers take several days to receive.
For more information on processing times, read Kyckr's registry guides.
What Information Is Provided?
Generally, the shareholder’s name, address and extent of holding is provided, but each country is slightly different.
The Cayman Islands only lists the shareholder at the company’s formation.
New Zealand only lists the main shareholders.
Quebec lists the three biggest shareholders, and not more.
The UK lists every shareholder.
Remember: Shareholder information can be unreliable. Many world-leading countries allow the use of non-disclosed nominee shareholders, which conceal the real shareholders, although some, like Singapore, require nominee status to be public.
What Documents Show Shareholder Ownership?
Verifying UBOs from shareholder disclosures can be split between two considerations: power and money. So:
Voting rights: A shareholder’s right to vote or remove the board, for example, can be found in Deeds of Incorporation, Memorandum and Articles of Association.
Financial ownership: A shareholder’s financial benefit from a legal entity can be found in share certificates and Confirmation Statements (in Companies House, for example).
Costs: These range from free company registry data and filings to purchasable shareholder registers, which, in Cyprus, cost €20, or $10 in Australia.
Can You Receive Shareholder Ownership Data Via API?
Just 13% of the world’s company registers (according to Business Registry Insights, 2025) offer shareholder data via a company register API. Those who do differ on who gets to access it:
New Zealand, for example, makes its API freely available.
Italy only makes it available to nationally registered entities.
Costs must be factored in: While New Zealand doesn’t charge pay-per-call, others don’t.
Bottom line: Most company registers, including UK Companies House, don’t offer shareholder data via API, making UBO verification a slow, expensive process costing upwards of $400 per entity.
Automated UBO Verification Powered by 300 Company registers
Kyckr's UBO Verify addresses these challenges by extracting shareholder data from global company registers – in real time.
Our proprietary algorithm matches the company’s shareholders to other entities and persons based on an index of registry data, immediately retrieving the next layer of data if a match is found.
UBOs are calculated according to a percentage threshold set by you.
Within seconds, you are presented with the calculated UBOs along with a structured data set, including profile information for all the intermediate shareholders found.
Book a demo – and start saving time and money now.