EU UBO Register Access 2026: Complete Guide to 6AMLD Compliance
European financial crime professionals are entering a brave new world.
Following the CJEU’s 2022 ruling, the EU has ended public access to beneficial ownership information for good, and the recently published Opinion of the CJEU suggests that shareholder data might also contravene the right to privacy.
Clearly, the EU is moving towards a system in which only those with a proven legitimate interest can access ownership data.
The new reality is stark: compliance teams must ensure legal, unified access to EU corporate ownership data, which Kyckr has been delivering since 2007.
But what is the new regime? And what can financial crime teams do to prepare for it? What are the timelines? The new requirements? Alternatives? This article explains everything.
The End of Public Access
As we’ve already seen, public access to beneficial ownership information is over. The 6AMLD saw to that.
Enacted in May 2024, the EU’s 6th Anti Money Laundering Directive (6AMLD) aims to harmonise the fragmented beneficial ownership system across the EU, in which 48% of countries offer limited access, 30% public, and the remaining third is restricted to local obliged entities and competent authorities.
Different EU member states differed in terms of what kind of data fields they offered (with some excluding nationality or beneficial nature entirely), as well as extremely varied processing times, costs, and procedures.
Think of the 6AMLD, therefore, not simply as an attempt to make information access more restrictive, but restrictive and harmonising.
The New System: Tighter, But More Standardised
The new system promises a lot of things in theory. But as we’ve seen since 2022, EU unity is rarely so simple in practice.
There are essentially two points that non-EU obliged entities must remember with the 6AMLD:
Restricting access to UBO information,
Standardising such access
Standardising the information being accessed.
Let’s go over each one.
Who Has Legitimate Interest Under the 6AMLD?
According to the 6AMLD, Article 12 (1), anyone involved in the “prevention or combating of money laundering” and terrorist financing has a legitimate interest, including academics, journalists, members of civil society, and “entities subject to AML/CFT requirements in third countries”.
How Will Access Be Given?
LIA UBO requests will usually be made on a case-by-case basis.
Electronic Access: Access “shall be granted through electronic means”, although physical UBO disclosures will be given to those “unable” to access it electronically (Article 12).
Processing Time: “From 10 November 2026”, UBO registers must provide a response within “12 working days”, though this may be extended by another 12 in the event of unusually high demand for UBO disclosures (Article 13).
Certification: Once access is granted, the entity will be granted a 3-year certificate, with requests answered within 7 days, not 12.
Repeated Access: Once LIA access has been granted, UBO registers must have “mechanisms in place to allow repeated access” without the need to verify “function or occupation” every time (Article 13).
Case Study: Denmark’s UBO register is already aligned with the 6AMLD. As of January 2026, LIA requests take up to 12 days to process.
Standardised Procedures and Templates
Currently, procedures for accessing beneficial ownership information via an LIA request vary widely across the European Union. According to Article 14, this is set to change.
EU-Wide Recognition: The Commission is looking to create “procedures to facilitate the mutual recognition” of LIA access, if granted in one Member State (Article 14). Think of it as a UBO version of an EU Blue Card.
Standardised Templates: These will be used by LIA requesters “for requesting access" to UBO data, a far cry from the extremely different systems currently.
Data Exchange: The Commission also wants to create “procedures” that will enable registers to “notify each other” of revocations.
Case Study (Sweden)
On 5 December 2025, Sweden’s Ministry of Finance issued legal advice regarding handling LIA requests. While just legal advice, not legislation, it is telling:
Legitimate interest access users won’t be given direct access to the UBO register but will be issued three-year LIA certificates.
Sweden will respect certificates from other EU jurisdictions.
Advises that Sweden shouldn't grant access to LIA requests from recipients not in an EEA country.
UBO requests on a case-by-case basis? No: “It shall be possible to obtain repeated access to data from the register on the basis of the certificate, without the profession or position having to be subject to a new assessment each time.”
What UBO Data Will Be Available?
According to Article 12, the information provided will be standardised:
Name
Month and year of birth
Country of residence
Nationality
Nature and extent of beneficial interest.
This is remarkably different from the current set-up. According to Transparency International, France doesn’t provide the UBO’s citizenship, while Spain doesn’t disclose the extent of their beneficial interest.
What About the Timelines?
10 July 2026: The “relevant provisions” must be transposed by Member States.
10 November 2026: UBO registers must provide a response to LIA requests within “12 working days”.
10 July 2027: All laws, regulations and provisions “necessary to comply with the Directive” must be brought into place by Member States.
Until then, it’s going to be a rocky road ahead.
Transposition of the 6AMLD So Far
While countries like Denmark have already transposed much of the 6AMLD into national law, others haven’t.
On Wednesday, 17 December 2025, Czechia fully closed its public beneficial ownership register until it had fully implemented the mechanisms and procedures of the 6AMLD.
According to official Czech guidance, legitimate interest access will only be possible via a court procedure.
What Will the New Regime Look Like?
As we saw with the fragmented situation after the 2022 CJEU ruling, EU Member States will do things differently. In fact, this is already plain.
While Sweden may not provide LIA access to third-country obliged entities, the Netherlands has already stated it will.
As Kyckr CEO Steve Lamb said in his article for The Paypers, “Cyprus is unlikely to offer easy cross-border access anytime soon.”
But several things are clear: LIA access is becoming the EU-wide model for beneficial ownership information, and standardisation is coming.
6AMLD Checklist For Financial Crime Teams
Adjust onboarding timelines: Build in 12–24 working days for UBO verification instead of instant lookups (effective 10 November 2026).
Document your legitimate interest: Prepare written justification showing how UBO access supports your AML/CFT obligations, as the burden of proof is on you.
Identify priority jurisdictions: Map which EU member states are critical to your operations and prioritise certificate applications accordingly.
Apply for LIA certificates early: Start with early adopters like Denmark and the Netherlands in Q1 2026 before the July rush.
Check third-country access policies: If you're outside the EEA, verify which member states will grant you access (Sweden may not, Netherlands will).
Budget for new costs: Account for LIA application fees, per-request charges, and administrative overhead replacing free/low-cost public access.
Monitor implementation progress: Track your priority jurisdictions monthly through July 2027 as transposition timelines vary widely.
Set certificate renewal reminders: Create alerts 90 days before three-year LIA certificates expire to maintain 7-day fast-track access.
Maintain Compliant Access to EU UBO Registers
Corporate ownership data can no longer be treated as open, standardised, or stable across jurisdictions.
Simply delivering data won't carry KYB operations through what's ahead. What counts now is understanding which data exists, how it can be lawfully obtained, under what frameworks, and within what boundaries.
In this context, value no longer stems from scraping what happens to be available, but from delivering compliant, verified access, and from surfacing limitations upfront rather than leaving them hidden.
This is the challenge Kyckr was designed to address, providing unified access to over 300 company registries globally, via the Kyckr Portal or API.