APAC’s UBO Landscape: What Legal Teams Should Know Now

From Tokyo to Sydney, governments across the Asia-Pacific region are tightening rules around who really owns and controls companies. But the level of transparency and how it’s enforced still varies widely.

Some countries like Japan and Australia have rolled out full PSC registers and are tracking foreign ownership. Others, like China, are just getting started, with limited disclosure focused mainly on financial and high-risk sectors. That inconsistency makes compliance across the region more complex than it looks on paper.

If your team manages entities across the APAC region, especially in sectors like finance, infrastructure or cross-border joint ventures, you’ll need to keep pace with how each country handles BO reporting and stay aware of where the blind spots are. Here’s a snapshot of how major APAC economies currently compare:

Regional Overview: What Key APAC Economies Require

What’s Driving the Push for Transparency in APAC

While FATF 24 and 25 continue to drive the push for transparency, APAC countries are taking different paths to get there. Australia’s new Beneficial Ownership Register, launched in 2024, marks a major step forward and is expected to tighten enforcement. 

Japan stands out for implementing a full overseas entity register, something only a few countries in the region have. Meanwhile, China’s recent registry, introduced in 2023, remains limited in scope and access, with disclosure focused mainly on high-risk sectors like finance and state-owned enterprises.

These differences highlight the complexity of managing compliance across the region and why a one-size-fits-all approach won’t work.

Where Most Teams Slip Up

Even in countries with strong frameworks, gaps remain. Common issues include:

• Reporting only direct shareholders and missing indirect control
• Overlooking trust ownership disclosures
• Assuming foreign entities aren’t in scope
• Treating UBO as a one-time filing instead of a process

With stricter enforcement on the horizon, even small oversights can result in penalties, delays or regulatory pushback.

Quick Compliance Check for APAC Entity Teams

Not sure where you stand? Use this checklist to find any weak spots before they turn into problems.

🗸 Are we identifying beneficial owners at or below the 25% threshold?

🗸 Are trusts included in our reporting framework across jurisdictions?

🗸 Are we tracking both domestic and foreign entities with significant control?

🗸 Do we understand PSC requirements and reporting timelines in each country?

🗸 Is our BO data reviewed regularly, not just at filing?

🗸 Are we storing documentation that can support an audit or inquiry?

🗸 Do we have internal processes for monitoring rule changes in each jurisdiction?

🗸 Is ownership data centralized and accessible to the right teams?

UBO compliance across APAC is evolving quickly but the rules, access and expectations aren’t consistent. Whether you operate in one country or across five, clarity matters.

Download the 2025 UBO Guide to get detailed breakdowns by country, key regulatory changes and tools to help you stay compliant across borders.