An ultimate beneficial owner (UBO) is an individual who ultimately owns or controls a company, directly or through a chain of other companies, trusts and arrangements. Every offshore company has information on its UBO: it is obtained by the registered agent, the bank and the payment provider, and in many countries also by a government register. The only difference is the circle of people who can access this information.
Who counts as a beneficial owner
Under the current EU Directive 2015/849, the indicator of direct ownership is a shareholding of more than 25% (25% plus one share) held by an individual; a holding of that size by a company controlled by an individual indicates indirect ownership. Control by other means counts on a par with shareholdings: voting rights, the appointment of management, agreements. If no beneficial owner is identified after all checks, the company’s senior managing official is disclosed, and the reviewer records the steps taken.
From July 10, 2027, Regulation (EU) 2024/1624 will apply in the EU. Its threshold is worded as 25% or more of the shares, voting rights or other ownership interest, and for indirect ownership the shares are multiplied along the chain and added up across all lines leading to the same person. Example: a person owns 60% of a holding company that owns 50% of an operating company; their indirect stake is 30%, so they are a beneficial owner.
Beneficial ownership (UBO) disclosure by jurisdiction
| Jurisdiction | Criterion | Who sees the data |
|---|---|---|
| EU | more than 25% or control (from July 2027: 25% or more) | authorities and obliged entities; general public access was struck down by the EU Court of Justice |
| United Kingdom (PSC) | more than 25% of shares or voting rights, the right to appoint a majority of directors, significant influence | public Companies House register, home address withheld |
| Hong Kong (SCR) | more than 25% of shares or voting rights, the right to appoint a majority of the board, significant control | register kept by the company, accessible to law enforcement authorities |
| BVI | 25% or more ownership or equivalent control (for access) | authorities; from April 1, 2026, persons with a legitimate interest |
| United States (CTA) | reports are filed only by foreign companies registered to do business in a state | FinCEN |
European Union. On November 22, 2022, in Cases C-37/20 and C-601/20 (WM and Sovim), the EU Court of Justice declared invalid the provision that opened beneficial ownership information to any member of the general public. Companies’ obligation to file and update data in the registers remains in place.
United Kingdom. A person with significant control (PSC) is someone with more than 25% of the shares or voting rights, the right to appoint or remove a majority of the directors, or significant influence over the company or a trust. Holdings are stated in bands: more than 25% up to 50%, more than 50% up to 75%, and 75% or more. A PSC’s home address is withheld and a service address is shown instead; in certain cases, an application to protect the information can be made. More on UK companies is on the UK company formation page.
Hong Kong. Since March 1, 2018, companies have kept a significant controllers register. It is kept at the registered office or another place in Hong Kong and made available to law enforcement authorities on demand; these include the Companies Registry, the IRD, the HKMA and the police. The obligations of a Hong Kong company are described on the Hong Kong offshore jurisdiction page.
British Virgin Islands. Since January 2, 2025, the BVI Business Companies and Limited Partnerships (Beneficial Ownership) Regulations, 2024 have applied: companies file beneficial ownership information, and the register is kept by the Registrar of Corporate Affairs. The BVI Government’s access policy allows requests from persons with a legitimate interest (money laundering investigations, customer due diligence by an obliged entity), with a fee of US$75 per request; the full regime has operated since April 1, 2026. Access is limited to persons with a stake or control of 25% or more. How this affects registration is described on the BVI offshore company page.
United States. According to FinCEN, companies created in the US and their beneficial owners are exempt from reporting under the Corporate Transparency Act. Reports are filed by foreign companies registered to do business in a state, unless an exemption applies to them; FinCEN’s final rule took effect on August 14, 2026.
Which documents to prepare
The bank and the agent request an ownership chart down to each individual with percentages, the documents of intermediate companies, identity documents and proof of address of the beneficial owners. If shares are held through a trust or a nominee shareholder, the trust deed or nominee agreement is required, together with an explanation of who actually makes the decisions. The full list is in the article on KYC and KYB documents.
A business example
A holding company is owned by another company, whose owner with a 20% stake controls decisions through a shareholders’ agreement. By shareholding, he is below the threshold, while by control he is a beneficial owner. The bank needs the full control route with a copy of the agreement, otherwise the review will drag on.
Common mistakes
- Confusing restricted public access to the register with anonymity: the agent, the bank and the authorities see the beneficial owner in any of the jurisdictions listed.
- Assuming that a nominee director or shareholder removes the real owner’s liability.
- Forgetting to notify the agent of changes in shareholdings and control: many regimes allow only a short period for this.
How Offshora helps
Financial institutions report a company's accounts and its controlling persons under the CRS standard; what this means for the owner is explained in CRS 2026: a note for the owner of a foreign company. How disclosure of owners affects asset protection structures is covered in the guide to asset protection, and the tax consequences of control in CFC rules.
Offshora helps build a structure with a clear ownership chart, prepare beneficial ownership information for the agent and the bank, and keep it up to date. To discuss your structure, send a request and specify the countries where the companies are registered and where the owners are resident.
Tell us about your task, and we will propose a jurisdiction, the scope of services and the order of work.
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