Ultimate beneficial ownership (UBO) registers in the European Union (EU) fall under three categories: public registers, legitimate interest access (LIA) registers, and non-LIA registers.

This division started in 2022, when the European Court of Justice ruled that publicly accessible beneficial ownership information contravened the right to individual privacy.

While a minority of EU member states kept beneficial ownership information public, most ended public access, only providing such information to nationally regulated obliged entities and the authorities. Many of them also provide beneficial ownership information to those who can prove a ‘legitimate interest’, such as overseas obliged entities and journalists.

But how can such access be granted? Each member state answers differently. The result is an incoherent and fragmented system offering varying accessibility, usability, and processing times.

Methodology: We used several ways to test each register. First, we incorporated the findings of Transparency International for ‘legitimate access’ routes. Second, we tested ‘public access’ routes between October 6-10, 2025.

This article breaks down the different beneficial ownership registers, how foreign obliged entities can access them, as well as the costs, processing times, information available, and alternative ways to verify EU-based UBOs.

Can Foreign Obliged Entities Access EU Beneficial Ownership Information?

In theory, yes. In practice, rarely.

37% of public access registers can only be accessed with a national ID, making access virtually impossible for foreign entities.

15% of EU UBO registers restrict access to national obliged entities and competent authorities.

48% offer access to those with a legitimate interest, but either insist on national language submissions, apply narrow substantive tests of “legitimate interest”, and require a national or eID.

In short: Non-EU obliged entities are often blocked from using the legitimate interest route as it stands.

Public Access

30% of the EU member states offer public beneficial ownership registers. In practice, however, Kyckr found that only two-thirds of those registers are available to anyone.

Several public registers (Bulgaria, Croatia, and Portugal) require a national ID to access beneficial ownership information.

Bulgaria

Bulgaria offers public UBO information on the online portal of the Commercial Register, including the UBO’s name and their shareholding size.

However, accessing more detailed information, such as addresses and certified documents, requires authentication via a qualified EU-recognised electronic signature, registry agency certificate (obtainable in person), or Personal Identification Code (residents-only).

Reforms: On 4th June 2025, Bulgaria adopted a law (decree no 92) to give access to those with a legitimate interest; however, it is unclear what that means.

Croatia

Croatia’s beneficial ownership register is public, but logging in requires authentication through NIAS, an official identifier available only to Croatian citizens, residents, or entities.

Foreign users without NIAS credentials cannot access it directly unless they have a local representative or a Croatian e-ID.

If your organisation often deals in Croatia, you can apply for a foreign e-ID recognised under eIDAS. Croatia is gradually expanding cross-border eID login support, but compatibility is still inconsistent.

Czechia

Czechia’s UBO register, the Evidence Skutečných Majitelů (ESM), is extensive and easily accessed online by anyone.

It is a separate register to the commercial register, and typing in a name brings up name, ID number, nature of control or ownership, nationality, country of residence, and even an ownership graph detailing the ownership structure.

Reforms: The Supreme Court ruled in late August 2025 that the country must align legislation with EU AML rules, limit public access to UBO data, and provide it only to those who pass a ‘legitimate interest’ access test. It also ruled that the state shouldn't enforce the submission of beneficial ownership information from legal entities/trusts until the legislation is amended.

Estonia

Estonia offers the most transparent UBO register in the EU.

Fully public beneficial ownership information is available on the E-Business Register, including name, shareholding, ownership graph, history, and address. No login is required. Such information is also available via API.

Reforms: Estonia is currently transposing the 6AMLD into national legislation; by 2026, it will offer a tiered access to beneficial ownership data.

Latvia

Latvia offers public beneficial ownership information, but it’s limited to name and shareholding unless users create an account and download critical documents.

Latvia is committed to keeping access public, even after the passage of the 6AMLD. However, its bulk datasets available haven’t been updated since July 2024.

Reforms: Public access is uncertain. Latvia asked the ECJ whether a legitimate interest access test must be applied when granting access to its shareholder register. If the court rules that GDPR requires that test to be applied, access may be restricted.

Poland

Poland’s UBO information is publicly accessible on a separate register, the Central Register of Beneficial Owners (CRBR, “Centralny Rejestr Beneficjentów Rzeczywistych”).

A search provides extensive information on the name, address, share size, country of residence, and citizenship.

Reforms: There is draft legislation being considered which will shift its access regime to be based on legitimate interest.

Portugal

Portugal’s RCBE, the official central register, only provides access to beneficial ownership information to those with a Portuguese e-ID.

However, these are only available to residents, citizens, and Portuguese taxpayers. In practice, therefore, it is impossible to access beneficial ownership information as a foreign entity without partnering with a Portuguese firm.

Reforms: On 17 October 2025, Portugal’s president approved a decree to change to a legitimate interest regime for RCBE, although the RCBE website has yet to be updated to reflect these changes.

Romania

Romania offers publicly accessible UBO information via the ONRC portal. Information is held with the Trade Register, requiring users to file a request, pay a fee, and provide an electronic signature.

Reforms: Following the 6AMLD, a draft law was proposed in August 2025 to limit public access to those with a ‘legitimate interest’.

“Legitimate Interest” Access (LIA)

Nearly half (48%) of EU member states have limited access to those who can prove a ‘legitimate interest’.

However, member states interpret this ‘legitimacy’ differently. Moreover, they differ on how a person with a legitimate interest might access that information.

Most member states provide beneficial ownership information on a case-by-case basis to those with a legitimate interest, with nationally regulated AML reporting institutions given automatic access to the register. A small number offer general access to the UBO database.

Austria

Austria’s UBO register provides UBO information on a strict case-by-case basis for €4 per entry.

Reforms: On October 1, 2025, Austria set out amendments to its Beneficial Owners Register Act (“Wirtschaftliche Eigentümer Registergesetz”), including new access rules for obliged entities and those with a legitimate interest.

The legitimate access rules have been clarified. It includes obliged entities in third countries, journalists, academics, and those entering a business relationship with a specific legal entity.

Belgium

Belgium provides beneficial ownership information on a case-by-case basis by email to those who can prove a ‘legitimate interest’ in doing so.

Foreign banks can apply for beneficial ownership information if they are entering an economic relationship or in litigation with an entity, according to Article 4, 23° of the law of September 18, 2017.

There are no fees. According to Transparency International, requests are processed by email within a week.

Denmark

Since 1 September 2025, Denmark has provided beneficial ownership information only to those with legitimate interest access instead of offering full public access. This includes the Danish authorities, Danish obliged entities, and the press.

This is one of the few EU countries where AML data aggregators remain permitted under LIA rules.

Finland

Finland applies legitimate interest access.

Foreign banks can request UBO information on a case-by-case basis via an online form for €30 or apply to become “contract clients” with the Finnish Patent and Registration Office, paying an initial €200 setup fee plus small per-extract charges. The applicant must justify the AML purpose and sign the data-use terms.

This is one of the most accessible LIA systems for foreign AML users, though approval remains discretionary. According to Transparency International, if the registry considers the requester lacks legal authority to represent the organisation, they will demand power of attorney.

France

France provides legitimate interest access through the Institut National de la Propriété Industrielle’s (INPI) LIA portal, but only after users have created an account.

According to the INPI, Assujettis non-UE (non-EU obliged entities) must provide a passport, proof of link to the requesting organisation, a national registration number, a completed and signed declaration form, as well as translated documentation providing AML responsibilities.

In practice, however, it isn’t so clear-cut. Transparency International reported that they had to send their completed application in French. Moreover, they were asked to provide a SIREN number, which is only available to French entities. It took 20 days to receive general access to the register.

Germany

Germany’s Transparenzregister provides beneficial ownership information on a case-by-case basis.

Applicants must register as an individual on behalf of an entity, detailing the specific legal need for access. Applications cost €1.65.

However, access is far from efficient. Transparency International reported it took one year for them to receive beneficial ownership information.

Hungary

Hungary’s UBO register offers information on a case-by-case basis.

According to Transparency International, their ‘legitimate interest’ could not be proven, and family, legal, ownership and business ties to the entity in question were requested.

Access costs €3.80 per extract and may take up to several months for beneficial ownership information to be provided.

Ireland

Ireland’s RBO accepts legitimate interest requests on paper, but none have been approved since public access ended.

Only Irish “designated persons” (banks, lawyers, accountants) can log in automatically and access the database. Those with ‘legitimate interest’ are dealt with on a case-by-case basis.

The RBO requires requesters to show proof that the entity is linked to high-risk jurisdictions or convicted individuals.

Lithuania

Lithuania offers two ways for legitimate interest access; however, both routes are limited to people or entities in Lithuania.

Users can access unique register filings on a case-by-case basis, each extract costing between €1.50 and €2.93. By signing a general contract with the registry, users receive general access to its JANGIS register and pay just €0.03 per extract.

Luxembourg

Luxembourg updated its UBO legal regime to introduce an LIA model in 2025, providing information on a case-by-case basis to journalists, NGOs, and persons entering transactions.

Each request costs €5 and must show a transactional link. The Ministry of Justice processes them manually, usually granting access to one company at a time.

Malta

Malta’s Registry of Beneficial Owners operates a case-by-case LIA model.

Requests must be emailed with an explanation of the AML reason, and approvals are one-off. Even successful applicants receive only a scanned extract, not database access. Each request costs €5.

Slovenia

Slovenia introduced LIA in August 2025, allowing beneficial ownership information on a case-by-case basis for AML and anti-money laundering purposes.

The register is managed by AJPES, and applications can be emailed with supporting documents.

There are no fees, and responses are relatively quick. The definition of legitimate interest is broad enough that a well-documented foreign bank could realistically succeed.

Spain

Spain’s Registro Central de Titularidades Reales offers a public UBO registry, but legitimate access for foreign reporting entities is virtually impossible.

Applicants must log in with a Spanish ID. All email exchanges must be in Spanish. It took Transparency International’s Spanish subsidiary 6 months to be granted access. Even then, UBO details excluded the nature of the beneficial ownership.

Sweden

Sweden’s UBO register provides legitimate interest access on a case-by-case basis.

It is accessible, according to Transparency International, but you require an eID. There are no fees.

Looking forward: Sweden says it will provide UBO data via API in the autumn of 2025. However, no update has been given.

Non-LIA Access

15% of EU member states have non-LIA registers, meaning that they only provide access to national authorities and “obliged entities” registered in their countries. This followed the CJEU ruling in 2022.

This includes:

Cyprus: The Cyprus beneficial ownership register ceased public access on January 3, 2023.

Greece: Greece suspended public access to its UBO register from 1 December 2022.

Netherlands: The Dutch government restricted public access to the UBO Register. A recent law will introduce LIA access, but the access rules haven’t been fully formed.

Slovakia: On 10 July 2025, the Statistical Office of the Slovak Republic officially discontinued public access to beneficial ownership (BO) data in that register.

Suspended Access

Italy

Italy’s beneficial ownership register exists in law but is effectively frozen awaiting two key court rulings.

Following legal challenges over privacy and compliance with EU rules, the Lazio Regional Administrative Court and later the Council of State suspended key parts of the regime in 2024, including company reporting obligations, accreditation of obliged entities, and access to the register itself.

Although the framework remains on the books, neither authorities nor financial institutions can currently consult or use the register, leading Transparency International to list Italy’s access status as “suspended”. A new decree introducing legitimate interest access is due to be gazetted soon. Follow-up regulations will be needed to establish the practical rules for verifying legitimate interest on a case-by-case basis.

Will the 6AMLD Change This?

The EU Commission passed the 6AMLD in May 2024 to make legitimate interest access an EU-wide standard and harmonise access rules for non-EU obliged entities.

A standard template for requesting UBO information.

UBO information presented as machine-readable data.

Accessible on a centralised register (BORIS).

Procedures for EU-wide register access once access is granted in one member state.

Timeline: Technical provisions on register design and UBO data access will hopefully be in place by 10 July 2026. Enforceable from July 2027 onwards.

However, member states will interpret the 6AMLD differently. The situation will likely remain fragmented and time-consuming for non-EU obliged entities.

Verify UBOs Without UBO Register Access

Kyckr provides instant access to global company registers, enabling record-retrieval of shareholder filings.

That’s not all. Our tool, UBO Verify, extracts shareholder data from official company filings. This allows our proprietary algorithm to match the company’s shareholders to other entities and persons using an index of registry data, and to immediately retrieve the next layer of data if a match is found.

Within seconds, you are presented with the calculated UBOs along with a structured data set, including profile information for all the intermediate shareholders found, as well as a PDF report and graph visualisation.

Spektr’s co-founder and CPO called it a “game-changer”: “Kyckr’s incredibly detailed UBO report helps us unravel complex ownership structures quickly, sometimes, instantly.”

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EU UBO Registry Access for Obliged Entities (2025 Guide)

Can Foreign Obliged Entities Access EU Beneficial Ownership Information?