UBO transparency isn’t just a regional push, it’s a global shift. Across Europe governments are tightening disclosure rules to make it easier to learn who’s in control. While EU countries follow a shared regulatory framework under EU anti-money laundering directives, how those rules are enforced and applied varies widely, and the UK has taken its own path post-Brexit.
High-impact economies like Germany, France and the UK reflect the growing complexity in different ways, especially since the UK’s regulatory framework now operates independently from the EU.
Still, these markets set the tone for how ownership transparency is evolving across the region. If you're operating in more than one country in Europe or managing a layered structure, understanding these differences is key to staying compliant and audit-ready.
Regional Overview: How the UK, Germany, France and Other European Countries Handle UBO Transparency
Under the EU’s 4th and 5th Anti-Money Laundering Directives (AMLD), member states must maintain central UBO registers and require companies and certain trusts to disclose who owns or controls them. This push for transparency isn’t just about checking boxes, it’s about stopping financial crime, tracing control across borders and closing gaps in ownership visibility. That’s where global standards like FATF 24 and 25 come in:
- FATF 24: Requires timely, accurate info on who owns or controls companies
- FATF 25: Applies the same expectations to trusts and similar legal setups
Together, they define what meaningful ownership transparency looks like and highlight where some countries still fall short.
Where the UK differs
The UK’s UBO rules follow many of the same principles. It adopted both the 4th and 5th AML directives before Brexit and continues to maintain a fully public People with Significant Control (PSC) register.
Since then, the UK has gone further on its own terms, introducing a Register of Overseas Entities and moving toward stronger identity checks for company filings. It’s no longer bound by new EU directives like the 6th AMLD, so over time, its approach may start to look different. But for now, it remains closely aligned on the fundamentals.
Here’s how six key European countries measure up:
The table highlights a few of Europe’s largest economies, but it’s just a snapshot. For a full breakdown of UBO rules across the region, including trust disclosure obligations, public access differences, and registry integration timelines, download the complete guide.
Compliance Check-in: Are You Covered?
This checklist covers the key areas where UBO compliance can break down. If you’re managing entities in more than one European country, it’s worth a quick audit.
Are we disclosing beneficial owners at the 25% threshold or lower where required?
Do we include trusts and foreign-owned entities in our filings?
Are we up to date on which registers are public vs. restricted and who can access what?
Have we identified our global ultimate parent firm across all jurisdictions?
Can we produce audit trails if regulators request proof of control or updates?
Is our ownership data centralized and easy to verify across all entities?
Have we trained internal teams on the reporting rules in key EU countries?
Do we understand country-specific access rules post-2022 CJEU ruling on public registers?
Are we tracking changes in beneficial ownership in real time, not just at annual filing deadlines?
Keeping Your BO Processes Tight
Getting a handle on UBO reporting starts with knowing where the biggest differences show up. These countries give you a clear read on how beneficial ownership rules work across Europe, both within and outside the EU, and where your process needs to flex.
Grab the full guide for a deeper dive into disclosure rules, trust reporting and what to watch for across Europe.
.svg)
-p-500.webp)
-p-500.webp)
-p-500.webp)
.webp)
