Beneficial ownership registers compared

Beneficial ownership registers differ first by access model: what natural-person control data is published to the general public, what remains gated to authorities or consented institutions, and what identity layers sit outside national registers. This research compares the UK PSC register publication model, the EU beneficial-ownership register access trajectory after AMLD5 and the Court of Justice judgment of 22 November 2022, and the United States FinCEN Beneficial Ownership Information (BOI) system as a non-public reporting database. It is definitional only. It does not describe how to search, mine, or monitor registers for deal or counterparty workflows.

Access models for beneficial ownership registers

Access models for beneficial ownership registers fall into three institutional patterns that desks must keep distinct: public publication with gated personal fields, central registers with restricted browse access after the CJEU judgment, and confidential competent-authority databases such as FinCEN BOI. GLEIF LEI data sits beside those registers as public entity identity, not as a national beneficial-ownership filing.

Public-publication regimes file control particulars on a searchable company register and disclose most fields to anyone, while holding selected personal fields on a private register. The UK Companies House PSC register is the worked example: Companies House states that the public register is available worldwide for free online search, that most PSC information is public, and that home address and full date of birth are not published. Protection applications can remove or restrict publication in defined cases.

Restricted-access central registers collect beneficial-ownership data for anti-money-laundering purposes but do not treat general-public browse access as the default. EU Member State registers were pushed toward unrestricted public access by Directive (EU) 2018/843. The Court of Justice held that AMLD obligation invalid on 22 November 2022 insofar as it required accessibility in all cases to any member of the general public. National access regimes then diverged from the prior "open to all" design.

Confidential reporting systems require entities to report beneficial owners to a competent authority that stores the data in a non-public database and discloses only to authorised recipients. FinCEN's BOI system is that model: FinCEN FAQs state that reported BOI is stored in a secure, non-public database, and that BOI is exempt from Freedom of Information Act disclosure. The Access Rule fact sheet states that the Corporate Transparency Act establishes BOI as confidential and may be disclosed only as authorised to defined recipient categories.

GLEIF's LEI sits beside these registers rather than inside them. GLEIF describes the LEI as a unique 20-character code linked to verified reference data, including ownership structure data in the Global LEI Index, answering "who is who" and "who owns whom" as a public-good identifier under ISO 17442. An LEI is not a national beneficial ownership register and does not replace PSC, EU RBO, or FinCEN BOI filings.

UK PSC register: what is public and what is gated

The UK PSC register is a public-publication beneficial ownership register: Companies House makes most PSC particulars searchable worldwide free of charge, while home address and full date of birth stay on a private register, and exceptional protection applications can suppress publication. Nature-of-control bands and service address remain the public control signal for UK entities.

Companies House defines a person with significant control as someone who owns or controls the company, sometimes called a beneficial owner. Nature-of-control conditions include more than 25% of shares or voting rights, the right to appoint or remove a majority of directors, and other significant influence or control. Share and voting bands are filed as over 25% up to and including 50%, more than 50% and less than 75%, and 75% or more. Confirmed particulars include name, date of birth, nationality, country of residence, service address, usual residential address, the date control began, confirmation date, and natures of control. Companies House guidance states that the home address must not be disclosed on the public register.

On publication, Companies House personal-information guidance states that most PSC information is available to the public, apart from home address and full date of birth. The Find and update company information service makes company data available to the public for free. Separate guidance on getting information about a company lists free company information such as registered address, officers, document images, mortgage charge data, previous names, and insolvency information.

Credit reference agencies and specified public authorities can request private information, including home address and full date of birth of PSCs, under the conditions Companies House describes. Some individuals may apply to protect PSC information from publication. Identity verification and a Companies House personal code are required for PSCs under the updated regime. Changes must be notified within 14 days of confirmation. If there is no PSC, the entity must file a statement explaining why the register is not blank of content.

For bank know your customer (KYC) and customer due diligence, UK PSC is a public control disclosure with withheld residential and full-birth-date fields, not a credit opinion on the ultimate beneficial owner (UBO).

EU registers after AMLD5 and the CJEU judgment

EU beneficial ownership registers follow a two-step institutional story: Directive (EU) 2018/843 required Member States to make beneficial-ownership information accessible in all cases to any member of the general public, and on 22 November 2022 the Court of Justice held that open-access mandate invalid as a disproportionate interference with Charter private-life and personal-data rights.

Directive (EU) 2018/843 amended the anti-money-laundering framework that required Member States to ensure information on the beneficial ownership of companies and other legal entities was accessible in all cases to any member of the general public. Luxembourg implementing law created a Register of Beneficial Ownership with internet-accessible fields and a mechanism for owners to seek restrictions in certain cases, as summarised in CJEU Press Release No 188/22.

In Joined Cases C-37/20 and C-601/20, the Court sitting as the Grand Chamber held that the AMLD provision requiring accessibility in all cases to any member of the general public is invalid. The Court stated that general public access constitutes a serious interference with the fundamental rights to respect for private life and to the protection of personal data, and that the interference was neither limited to what is strictly necessary nor proportionate to the objective pursued. The press release contrasts that invalid open-access design with the former regime, which combined access by competent authorities and certain entities with access by persons or organisations able to demonstrate a legitimate interest.

Directionally, official EU materials therefore no longer support treating unrestricted general-public browse access as the governing rule. Member State access after the judgment is a national implementation question. This research does not assert a single harmonised EU public-access model for 2026, because post-judgment national gate designs were not fetched here as a complete comparative set. Desks should separate three layers when mapping an EU counterparty: the central register's existence, the legal access gate, and the personal fields actually released under that gate.

US FinCEN BOI: confidential reporting, not a public register

The United States federal BOI system is a confidential reporting regime: FinCEN stores reported beneficial ownership information in a secure non-public database, exempts it from FOIA disclosure, and may disclose it only to authorised recipient categories under the Corporate Transparency Act Access Rule, not to the general public as a commercial register.

FinCEN administers Beneficial Ownership Information reporting under the Corporate Transparency Act. The Access Rule fact sheet states that the CTA establishes BOI as confidential and may not be disclosed except as authorised, and lists six recipient categories: federal agencies engaged in national security, intelligence, or law enforcement activity; state, local, and Tribal law enforcement agencies; foreign requesters meeting specified criteria via federal intermediaries; financial institutions using BOI to facilitate customer due diligence requirements under applicable law; federal functional regulators and other appropriate supervisory agencies assessing those CDD requirements; and Treasury officers and employees. Each category is subject to security and confidentiality protocols. Financial-institution access under the Access Rule is framed around CDD compliance with reporting-company consent, not general market research.

Reporting perimeter facts must be kept current and separate from access facts. FinCEN states that on 11 August 2026 it issued a final rule making permanent the reporting exemptions first introduced in its interim final rule of 26 March 2025: US companies are exempt from BOI reporting, and reporting companies do not report BOI for US person beneficial owners.

Reporting under the revised definition covers entities formed under foreign law that have registered to do business in a US State or Tribal jurisdiction, subject to the exemptions and deadlines stated on FinCEN's BOI pages. FinCEN also states that it will delete beneficial ownership information previously reported by US persons who are now exempt under the final rule, removing that data from the BOI database without requiring a deletion request from the business owner. Access remains gated to authorised recipients even for reports that are still required.

State secretaries of state maintain entity filing systems with varying public fields. FinCEN materials cited here do not establish a single nationwide public beneficial-ownership register equivalent to the UK PSC public register.

How desks should classify register access

Bank desks classifying beneficial ownership registers should label the access model before treating a field as public evidence: public publication with gated personal fields, restricted central-register browse after the CJEU judgment, confidential competent-authority databases, or LEI reference data. Publication status answers what is institutionally disclosed; it does not answer creditworthiness or sanctions status.

A working classification for credit and financial-crime files is:

• Public-publication with gated personal fields: UK PSC style. Control particulars and service address are public; home address and full date of birth are private; protection may suppress publication.
• Central register with restricted public browse: EU post-CJEU trajectory. Register existence remains; unrestricted general-public access is not the valid EU-law default after 22 November 2022.
• Confidential competent-authority database: US FinCEN BOI. Reportable population is defined by FinCEN rules; disclosure is limited to authorised recipients; FOIA does not open the database.
• Identity and ownership reference layer: GLEIF LEI. Public entity identification and "who owns whom" reference data, not a substitute PSC, RBO, or BOI filing.

That classification belongs with beneficial ownership, UBO, LEI, and the sanctions and AML trade finance hub. It does not authorise product-style register mining.