UBO register: who can see the owner of your company
A UBO register is an official record of the living people who ultimately own or control a company, usually anyone with 25% or more, or the power to control it in another way.
Almost every country now keeps one. The real difference is who may look: anyone, people with a legitimate interest, banks, or only the authorities. Of the 28 registers below, two are open to the public.
If you own a company, your name is on at least one beneficial ownership record somewhere, even if the company is in a place famous for privacy. That is not a problem in itself. What you want to know is where that record sits, who can open it, and what happens if you file it late. This page answers all three for every register Heirson works with, from the law or the registry itself.
Key takeaways
- FATF Recommendation 24 requires every country to make owner data available to authorities "rapidly and efficiently". Public access is optional, and most places chose not to offer it.
- The EU's open registers ended with the CJEU ruling of 22 November 2022. Access now runs through a legitimate interest test, with answers due within 12 working days from 10 November 2026.
- The UK PSC register stays fully public, with home address and full date of birth hidden.
- Since March 2025, companies formed in the US don't report owners to FinCEN. Only foreign companies registered in a state do, within 30 days.
- Several offshore centres use a 10% threshold, not 25%: the BVI (for filing), Seychelles, Bahamas, Belize and Bahrain.
- Deadlines run from 14 to 30 days in most places, and late filing fines are counted monthly or daily.
What is a UBO register?
The ultimate beneficial owner (UBO) is the natural person at the end of the chain: not the nominee shareholder, not the holding company, but the human who owns or controls it. A UBO register, also called a beneficial ownership register, PSC register, register of significant controllers or transparency register, is the official list of those people for each company. The glossary entry has the short version.
Registers exist because of FATF Recommendation 24, revised in March 2022. It requires "adequate, accurate and up-to-date information on the beneficial ownership and control of legal persons" that authorities can obtain "rapidly and efficiently", through a register or an alternative mechanism. Countries may make it public. They don't have to.
Here is what a typical entry holds, and the part most registers hide from anyone outside the authorities:
Beneficial owner record: Example Holdings Ltd
- Full name
- A. N. Example
- Nationality
- Portuguese
- Date of birth
- 03 / 1984 14
- Country of residence
- Portugal
- Home address
- Rua de Exemplo 10, Lisboa
- ID or passport no.
- P1234567
- Nature of interest
- Owns 100% through a BVI holding company
- Date became owner
- 2026-11-13
Every serious jurisdiction keeps the owner's name for the authorities. What varies is whether anyone else may look.
Who counts as a beneficial owner: the 25% and control tests
Most registers test in the same order, the order FATF and the EU use:
- Ownership. Anyone holding more than 25% of the shares or votes, directly or through other companies. The EU AML Regulation moves this to "25% or more" from 10 July 2027.
- Control by other means. Anyone who can appoint or remove most directors, or who exercises "significant influence or control", whatever they hold. This catches the person behind a nominee shareholder: the UK and Hong Kong rules count a nominee's shares as the nominator's.
- Senior managing official. If nobody passes either test, the register records the top manager instead, so the entry is never blank.
The ownership test looks through holding companies. Multiply the percentages down the chain to find your share in the company at the bottom. Try your own structure:
Look-through calculator
You own part of a holding company, which owns part of the operating company. Which registers would name you?
Arithmetic only. Many laws count you as owning everything a company holds once you control it (more than 50% in the UK PSC rules), and any control right beyond shares can name you at 0%. Check the rule in the table for your country.
Holding companies don't reset the count. Multiply down the chain, and remember that control can name you without any shares at all.
UBO registers by country: 28 compared
Every jurisdiction Heirson forms companies in, plus the UK and the US federal rule. Click a column heading to sort, or filter by who can see the register. Each row links to the law or the registry it comes from, and to our page for that country.
| Register and who keeps it | Source | ||||
|---|---|---|---|---|---|
| United Kingdom | PSC register, filed at Companies House | More than 25%, or control | PublicName, nationality, month and year of birth, service address, nature of control | Companies House within 14 days of a changeNew PSCs verify identity within 14 days | GOV.UK PSC guidance |
| Gibraltar | Register of Ultimate Beneficial Owners | More than 25% | PublicName, month and year of birth, nationality, residence, nature of interest; re-enacted 14 July 2026 | 30 days from incorporation | 2017 Regulations, r.8 and r.26 |
| BVI | Filed with the Registrar by the registered agent, since 2 January 2025 | 10% for filingLegitimate interest searches show 25%+ owners only | Legitimate interestSince 1 April 2026, US$75 per search: AML investigations, criminal proceedings, obliged entity due diligence | 30 days from incorporation; changes within 30 days | BVI Business Companies Act, s.96A, BVI FSC |
| Cayman Islands | Central platform, filed through the company's corporate services provider | 25% or more, or control | Legitimate interestSince 28 February 2025: journalists, researchers, counterparties; search by company name only | Changes confirmed within 30 days; monthly filing cycle | BOT Act (2026 Revision) |
| Bermuda | Kept by the company and filed with the Registrar through a licensed provider | 25% | Legitimate interestBanks see the full entry; legitimate interest applicants four fields, from September 2026 | 30 days | Beneficial Ownership Act 2025 |
| Malta | Register of Beneficial Owners at the Malta Business Registry | More than 25%, or control | Legitimate interestFrom 10 July 2025: name, month and year of birth, residence, nationality, interest; answer in 12 working days | Not stated in our sources | S.L. 386.19, reg. 5 and 7 |
| Bulgaria | Beneficial owner entry in the Commercial Register | Not stated in our sources | Legitimate interestBy law since 2025 (ДВ бр. 49/2025); practice reported to be uneven | With the registrationSeparate filing only if owners are not already the listed shareholders | Measures against Money Laundering Act, art. 63 and 63b |
| Cyprus | UBO register at the Registrar of Companies | 25% plus one share, or control | Banks and authoritiesPublic access suspended after the 2022 ruling; obliged entities pay EUR 3.50 | 90 days from incorporationConfirmed every year, 1 October to 31 December | Registrar UBO FAQ |
| Estonia | Beneficial owner data in the e-Business Register | Not stated in our sources | Banks and authoritiesFrom 10 July 2026 removed from open data; approved partners via an API with e-ID login | Not stated in our sources | RIK notice, 4 June 2026 |
| Switzerland | Federal Transparency Register, from 1 October 2026 | Not stated in our sources | Banks and authorities"Nicht öffentlich zugänglich"; banks and AML intermediaries can consult it; registration free | Changes reported on an ongoing basis | Federal Office of Justice FAQ |
| Isle of Man | Beneficial Ownership Database, filed by the nominated officer | 25% or more, then control, then senior manager | Banks and authoritiesObliged entities since 31 December 2024; legitimate interest only consulted on (May 2026) | 21 days | Isle of Man Government |
| Jersey | Central register at the JFSC Registry | 25% or more, lower where risk is higher | Banks and authoritiesObliged Entity BO register for due diligence; legitimate interest consulted on | Changes within 21 days | JFSC guidance |
| Guernsey | Filed with the Registry by the resident agent | More than 25%, or control | AuthoritiesNot public; legitimate interest access proposed (consultation closed 10 April 2026) | 14 days | Guernsey Registry |
| Panama | Private single register of final beneficiaries, filed by the resident agent (Law 129 of 2020) | 25% | AuthoritiesNot public; the agent and two officials who serve the authorities | 15 business days from formationChanges: company tells agent in 15 business days, agent updates in 5 | Law 129 of 2020, arts. 11 and 12 |
| Seychelles | Kept by the registered agent and uploaded to the FIU's central database | 10% or more, or control | AuthoritiesThe authorities listed in the Act | 14 days after creating the register or any change | BO (Amendment) Regulations 2025 |
| Bahamas | Registered agents' databases, linked through a secure search system | 10% | AuthoritiesNot open to banks or private firms; no legitimate interest route found | Changes to the agent within 15 days | Register of Beneficial Ownership Act 2018 |
| Belize | Filed with the Registrar since 2023 | 10% or moreFrom a summary of the AML Act | AuthoritiesThe agent and the authorities; not open to the public | Not stated in our sources | BCCAR legislation |
| UAE mainland and free zones | Real beneficiary register under Cabinet Decision 109 of 2023, kept with the licensing authority | 25% or more, or control | AuthoritiesCovers companies "including those in commercial free zones" | Changes within 15 days | Ministry of Economy |
| RAK ICC | Kept by the certified registered agent (BO Regulations 2019) | 25%, or control | AuthoritiesRAK ICC and competent authorities | 15 daysFrom summaries of the Regulations | RAK ICC BO Regulations 2019 |
| Labuan | Filed with the Registrar by the Labuan trust company | 25% | AuthoritiesLabuan FSA, the owner and people the owner authorises | 30 days from incorporation and each changePlus a yearly filing by 31 January | Labuan FSA BO Guidelines |
| Mauritius | Filed with the Registrar of Companies | Not stated in our sources | AuthoritiesFinancial crimes, police and FSC access, per summaries | 14 days from the share register entry | CBRD statutory obligations |
| Curaçao | Closed central UBO register at the Chamber of Commerce, since June 2024 | Not stated in our sources | AuthoritiesDesignated authorities; each owner can see their own entry | Notary files within two weeks of the deed | Landsbesluit UBO-registratie |
| Hong Kong | Significant Controllers Register, kept by the company in Hong Kong; not filed | More than 25%, or control | AuthoritiesOpen to law enforcement officers on demand | Kept up to date; nothing to fileNeeds a Hong Kong designated representative | Companies Registry SCR FAQ |
| Bahrain | Ultimate beneficial owner record with the Ministry of Industry and Commerce | 10% or more, or control | AuthoritiesShareholders themselves are public on Sijilat | Update "immediately", confirm yearly | Ministerial Order 83 of 2020 |
| Nevis LLC | No central register. Registered agents hold owner records under the AML Regulations | Agent's due diligence | No central registerAuthorities on request; no public access | Register copies at the agent updated within 15 days | Nevis FSRC |
| Marshall Islands | No central register. The entity keeps its own record and attests yearly | More than 25%, then control | No central registerProduced to the registrar's agent on demand | 60 days to produce it when asked | IRI corporate FAQs |
| Georgia | No beneficial ownership register found | Not applicable | No central registerOwners and directors are public in the company registry anyway | Not applicable | Law of Georgia on Entrepreneurs |
| United States (FinCEN) | FinCEN BOI database. US-formed companies exempt since March 2025 | 25% or more, or substantial control | None for US LLCsForeign companies registered in a state: FinCEN and authorities | Foreign companies: 30 calendar days after registeringWyoming, Delaware, New Mexico, Florida and Nevada LLCs: none | FinCEN BOI |
Showing all 28 registers. Rows marked "from summaries" rest on a law firm or provider summary of the law; the rest on the law, the regulator or the registry. As at 13 November 2026.
Privacy today is about access, not existence. Pick a register by who can open it, and expect your bank to see it either way.
The EU UBO register after the 2022 court ruling
From 2020 the EU required every member state to open its register to "any member of the general public". On 22 November 2022 the Court of Justice struck that rule down in WM and Sovim (C-37/20 and C-601/20), holding that open access was a serious interference with the rights to privacy and data protection. Luxembourg, the Netherlands, Austria, Ireland, Cyprus and Malta were among the states reported to have closed or limited their registers soon after.
The EU then rebuilt access around a legitimate interest test in the sixth AML Directive, Directive (EU) 2024/1640, and moved the rules on who is an owner into a directly applicable AML Regulation (EU) 2024/1624:
- 22 November 2022Public access "in all cases" declared invalid. Registers close or restrict.
- 10 July 2025National law must give access to anyone who can show a legitimate interest: at least name, month and year of birth, country of residence, nationality and nature and extent of the interest (Art. 74).
- 10 July 2026Full access rules due (Arts. 11, 12, 13 and 15): authorities get immediate, free, unfiltered access without alerting the company; banks get timely access during due diligence.
- 25 September 2026The Commission sends formal notices to 18 member states for incomplete transposition, as reported in the specialist press.
- 10 November 2026Registers must answer a legitimate interest request within 12 working days, extendable in surges.
- 10 July 2027The AML Regulation applies: ownership threshold "25% or more", changes reported within 28 calendar days, and the rest of the Directive in force.
Who has a legitimate interest?
The Directive presumes one for journalists and civil society working on money laundering, academics, anyone likely to do a deal with the company, banks outside the EU doing due diligence, and several public bodies. Others can apply case by case. The company is not told who looked, but the register logs access, and an owner can ask for the occupation of a journalist or NGO that searched. Owners at real risk of fraud, kidnapping, violence or harassment can ask for an exemption (Art. 15).
EU registers are closed to the curious, open to anyone with a reason. Expect a counterparty or reporter to be able to find you.
UK PSC, US FinCEN and the offshore registers
United Kingdom: still public, now with ID checks
The UK left the EU before the ruling and kept its persons with significant control register open. Anyone can see a PSC's name, nationality, month and year of birth, service address and nature of control. A PSC is anyone with more than 25% of shares or votes, the right to appoint or remove most directors, or significant influence or control. Since 18 November 2025, PSCs must also verify their identity with Companies House; a new PSC does it within 14 days of being added. See our UK limited company page.
United States: the federal register shrank
The Corporate Transparency Act started BOI reporting in 2024. An interim rule of 26 March 2025, made final from 14 August 2026, exempted every company formed in the US and every US person. Today only foreign companies registered to do business in a state file, within 30 calendar days. A Wyoming or New Mexico LLC owned from abroad files nothing with FinCEN, but its owner still appears on the EIN application and on Form 5472 each year, and every US bank still identifies owners.
Offshore centres: registers built for the authorities
The classic offshore centres all keep owner data, almost always away from the public. The BVI moved filing to the Registrar on 2 January 2025 and opened paid legitimate interest searches on 1 April 2026. Cayman opened legitimate interest access on 28 February 2025, searchable only by company name. Panama, the Bahamas, Seychelles and Belize keep registers for the authorities alone. Hong Kong asks the company to keep its own register in the city for officers to inspect. Nevis and the Marshall Islands have no central register at all: the agent or the company holds the record and hands it over when asked.
None of this makes an owner invisible. It decides who can find you without a court order. Our guide to anonymous companies sets out what privacy is still legal, and the nominee director guide explains why nominees don't change the register entry.
The UK is public, the US federal register skips US-formed LLCs, and offshore registers serve the authorities. Your bank sees you in all three.
Who sees what: from the public to your tax office
Think of owner data as a ladder. Each rung up sees more, and the top rung sees you wherever the company is formed:
The CRS and its list of participating countries explain rung five. It is the one that matters for tax, and it doesn't depend on any register being public.
Choosing a private register keeps you off the internet. It never keeps you from your bank or your own tax office.
UBO filing deadlines and late fines
Your registered agent usually files the first entry as part of formation. The duty that catches owners out is the change: a share sale, a new partner, a trust taking over the shares. Tell your agent the same week. These are the published fines for missing it:
Ownership changes trigger the deadline, not the calendar. Tell your agent within a week and the fines never start.
UBO register questions, answered
What does UBO stand for?
Is the UBO register public?
How do I find the UBO of a company?
Does a nominee shareholder change the UBO entry?
Does a US LLC have to report its owners in 2026?
Who files the UBO information?
Is there a UBO threshold lower than 25%?
Heirson (2026). "UBO registers by country: who can see the owner of your company." https://heirson.com/ubo-register/ (updated 13 November 2026).Changelog
- 13 November 2026: first published, with 28 registers from the laws, regulators and registries linked in the table, Directive (EU) 2024/1640, the CJEU judgment of 22 November 2022 and FinCEN's BOI rule as final from 14 August 2026.
We file your owner details. You choose how public they are.
Every company we form has its beneficial owner filing done by the registered agent, on time. Pick a place by who can see the register.