EC ¦ Commission takes action to ensure complete and timely transposition of EU directives

EU Steps Up Enforcement on Beneficial Ownership Transparency: Infringement Actions Against 11 Member States

A coordinated push by the European Commission to strengthen the fight against money laundering and terrorist financing is underway, as Brussels launches infringement procedures against several EU countries that missed a key legal deadline to ensure comprehensive access to beneficial ownership information. The move underscores the Commission’s resolve to close transparency gaps that can be exploited by criminal networks and to align national frameworks with EU standards.

Missed Deadlines and Formal Notices

The Commission has begun formal action against Member States that failed to notify national measures transposing multiple EU Directives into domestic law after the recent deadline expired. As a first step, letters of formal notice have been sent, giving the countries two months to respond and finalize transposition. If they do not provide a satisfactory reply or complete the process, the Commission may escalate to a reasoned opinion — the next stage in infringement proceedings — which can ultimately lead to referral to the Court of Justice of the European Union.

Bastian Schwind-Wagner_Follow "The European Commission has launched infringement procedures against 11 Member States for missing the July 2025 deadline to ensure comprehensive access to beneficial ownership information under the 6th AML Directive. These countries now have two months to complete transposition or face escalation to a reasoned opinion."

Focus on Beneficial Ownership: The 6th AML Directive

The centerpiece of the current action involves the 6th Anti-Money Laundering Directive (Directive (EU) 2024/1640), which overhauls organizational and institutional elements of the EU’s AML/CFT preventive framework. The Directive is phased, with staggered implementation dates. Although the majority of provisions must be transposed by 10 July 2027 — when the 4th AML Directive, as amended by the 5th, will be repealed — an earlier milestone fell on 10 July 2025. By that date, Member States were required to guarantee comprehensive access to beneficial ownership information for legal entities, trusts, and similar arrangements, including access for persons with a legitimate interest.

Eleven Member States — Belgium, Denmark, Germany, Estonia, Greece, Italy, Cyprus, Croatia, Poland, Slovakia, and Sweden — have not fully notified measures implementing this requirement. As a result, the Commission has issued letters of formal notice to these countries, starting the clock on a two-month deadline to close the gap and inform the Commission of their completed transposition.

Why Beneficial Ownership Matters

The beneficial owner register framework is central to AML efforts. Transparent, accessible registries reduce the anonymity that fuels money laundering, tax fraud, corruption, and the financing of terrorism. When registers are incomplete, hard to access, or insufficiently verified, criminals exploit shell companies, nominee arrangements, and complex trust structures to move and disguise illicit funds across borders.

Comprehensive access is not merely a matter of open data; it is about timely, accurate, and usable information. The Directive requires access for competent authorities, obliged entities, and persons with a legitimate interest — such as journalists and civil society actors investigating wrongdoing — reflecting a balanced approach to privacy and public interest. The Commission’s action signals that partial transposition or delayed implementation leaves serious vulnerabilities in national and EU financial systems.

The Legal Path: From Notice to Reasoned Opinion

The infringement procedure is structured and progressive:

• Letter of formal notice: The Commission requests the Member State to provide observations and remedy the non-compliance within two months.
• Reasoned opinion: If the response is inadequate or the transposition remains incomplete, the Commission can issue a reasoned opinion detailing the legal breaches and setting a new deadline.
• Court referral: Continued non-compliance may lead to a case before the Court of Justice and potential financial penalties.

This enforcement cycle is designed to encourage swift compliance while preserving legal clarity and proportionality. It also provides transparency to market participants and institutions that depend on predictable AML standards.

Implications for Financial Crime Compliance

For financial institutions, professional service firms, and obliged entities under AML laws, delayed national transposition creates uncertainty and operational risk. The absence of clear, harmonized access to beneficial ownership information complicates customer due diligence, beneficial owner identification, and ongoing monitoring — particularly for complex corporate and trust structures. It can also affect cross-border business, where mismatched national rules and registry access slow onboarding and increase compliance costs.

The Commission’s action is likely to accelerate national legislative and technical work on registers, verification processes, interconnection of registries, and access protocols. Compliance leaders should anticipate updates to local guidance, portal functionalities, legitimate interest criteria, and data verification standards. Firms should review policies to ensure they capture newly accessible data, integrate registry queries into workflows, and maintain audit trails for due diligence steps tied to beneficial ownership checks.

Next Steps for Member States and Industry

Member States under notice have two months to remedy non-compliance and notify the Commission of completed measures. That will likely involve:

• Finalizing legislative amendments to align access rights, verification requirements, and registry scope with the Directive.
• Upgrading registry systems to ensure usability, data quality, and secure access for authorities, obliged entities, and persons with legitimate interest.
• Clarifying processes for data corrections, sanctions for false filings, and cooperation with Financial Intelligence Units and supervisors.

Industry participants should track national consultations, regulator circulars, and registry announcements. Early engagement with registry operators and testing of access interfaces can reduce disruption. Where legitimate interest pathways are introduced or expanded, organizations should prepare documentation and workflows to request access efficiently and lawfully.

A Turning Point for AML Transparency

The gradual implementation of the 6th AML Directive is intended to prevent vulnerabilities and ensure consistent standards across the EU. By enforcing the July 2025 milestone on beneficial ownership access, the Commission is prioritizing one of the most effective tools against complex financial crime schemes. Whether Member States meet the two-month deadline will influence the pace of Europe’s AML modernization and signal how serious the bloc remains about closing loopholes exploited by criminal networks. The coming months will test governments’ capacity to deliver, and firms’ readiness to adapt.

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