EC ¦ Implementing Regulation on Formats for Submitting Beneficial Ownership Information

EU sets common data formats for beneficial ownership registers

The European Commission has adopted Implementing Regulation (EU) 2026/2354. It lays down common formats for submitting beneficial ownership information to the central registers, together with a checklist of minimum requirements a submission must meet before a register can accept it. The Regulation is based on Article 10(6) of Directive (EU) 2024/1640 (AMLD6), was published in the Official Journal on 22 October 2026 and applies from 10 July 2027, the same day as the Anti-Money Laundering Regulation (EU) 2024/1624 (AMLR). In practical terms, it turns the question of who the beneficial owner is into a defined set of data fields, selection lists and file uploads that registrants in every Member State will complete in the same way.

Why formats matter for register quality

Beneficial ownership registers have long collected the same categories of information in different shapes. One register stores a full name in a single field, another splits first names and surnames, a third accepts free text for the nature of control. Records entered this way are hard to verify and rarely match across borders, which is where money laundering schemes built on layered corporate vehicles tend to operate.

The AMLR already sets out what information must reach the registers, and the new Regulation fixes the format in which it arrives. Its stated aims are clarity for reporting entities, consistent data quality and greater interoperability between the central registers. Investigators tracing the proceeds of fraud, corruption or tax crime through companies and trusts in several Member States need records that match on something as basic as a date or an address, and today they often do not.

Bastian Schwind-Wagner _Follow

"For years, beneficial ownership registers across the EU have collected roughly the same information in very different shapes, which made cross-border matching slow and discrepancies easy to explain away. Fixed formats, a mandatory organisational chart for layered structures and a checklist that lets registers reject incomplete filings give the registers a real data-quality floor for the first time.

The work for registrants starts now, not in July 2027. Corporate service providers, fund administrators and trustees should test their records against the new data points, from the exact nature of control to nominee arrangements and trust deed details, while obliged entities should expect discrepancy reporting to become more precise and harder to avoid."

A standard data set for every beneficial owner

For each beneficial owner, registers will collect all first names and surnames in full, place and date of birth, residential address, country of residence, nationalities, and the type, number and issuing country of an identity document. Countries are chosen from a list based on ISO 3166-1 alpha-3, nationalities allow multiple choices and include a “stateless” option, dates use the yyyy-mm-dd format, and addresses follow a fixed structure in which street, city, postal code and country are mandatory.

National personal identification numbers, tax identification numbers and the Legal Entity Identifier are left out of the format rules because they already follow established formats. They must still be submitted wherever available. Member States may also collect additional data points for purposes other than those of AMLD6, for example to support customer due diligence or to address a specific national risk.

If a beneficial owner has died, that fact may be recorded instead of the personal details other than the names. Data submitted while the person was alive stays in the register under the ordinary retention rules. The same personal-data formats apply to senior managing officials.

Ownership interest and the many routes to control

The beneficial interest is broken down into structured elements. Ownership is recorded as direct, indirect or both, and the percentage of ownership interest is given to two decimal places. For legal entities, the beneficial owner’s role is selected from options that include founder, member of the management body in its management or supervisory function, beneficiary and any other person exercising direct or indirect control.

The nature of control is captured through nine options: ownership, voting rights, appointment rights, veto rights, distribution of profits, formal or informal agreements, family relationships, acting in concert to control a majority of voting rights, and nominee arrangements. In many money laundering and sanctions evasion cases, family ties, side agreements or nominees are the actual source of control over a company whose shareholder register looks unremarkable, and the list gives each of them its own entry. Registrants must also state the date from which the beneficial interest has been held.

Trusts and similar arrangements get their own vocabulary

Legal arrangements receive the most detailed treatment. Parties identified as beneficial owners are recorded by role: settlor, trustee, beneficiary, object of a power, default taker, protector or any other person exercising ultimate control. To prevent diverging interpretations, the recitals fix when each role’s beneficial interest begins. For a settlor it is the date the trust comes into existence, for a trustee or protector the date of appointment, and for beneficiaries the date they are named in the deed or identified by the trustee of a discretionary trust.

Each arrangement is registered with its name, a unique identifier and the trust deed or equivalent, uploaded with any addenda and binding documents. Where no deed exists, the registrant gives a general description and adds the type of settlement, the governing law, whether the arrangement is revocable, any powers reserved by the settlor, the duties and powers of the protector, excluded persons and the date of the original settlement.

Risk assessors will look closely at two further fields. The purpose of the arrangement is chosen from real estate, securities and liquidity management, inheritance management, mixed assets and charitable purposes. The value of the assets is reported in seven bands, from less than EUR 1,000 to more than EUR 50 million. Registrants also give the trustee’s place of residence and, where different, the place of administration. For discretionary trusts, objects of a power and default takers must be named where they can be identified individually, or described where they form a class.

Investment funds: a tailored derogation

Collective investment undertakings sit uneasily in a model built around operating companies and family trusts, so the Regulation gives them a separate format for the beneficial interest. It covers the direct or indirect holding of units as a percentage to two decimal places, the ability to define or influence the investment policy, and control of the fund’s activities through other means. The last two can be provided as text or as a file upload.

In fund structures, the person who can steer the investment policy is often more relevant than whoever holds the largest block of units. Recording that influence as a data point of its own gives registers and obliged entities in fund centres such as Luxembourg a firmer basis for identifying who actually controls a fund.

Organisational charts for complex structures

Where a legal entity or arrangement belongs to a structure with more than one entity or arrangement, the submission must describe the ownership and control structure, either as a visual representation (the organisational chart) or as structured data.

The chart must show the names and, where applicable, registration numbers of every entity and arrangement that owns or controls the registrant, and whether each is a legal entity, a legal arrangement, a nominator or a nominee. It names natural persons acting as nominees, states whether ownership or control is direct or indirect, specifies the means of control and gives ownership percentages to two decimal places. It also has to show how the beneficial owners relate to each entity and arrangement in the chain. Where ownership is so dispersed that no one has a controlling interest or control by other means, proof of that dispersion can be filed instead.

The recitals allow registers to collect information on complex structures in other formats as well, through structured or unstructured fields or file uploads, so that practice can develop. Whatever the format, a multi-layered structure can no longer be filed as a single entry with nothing visible behind it.

Non-EU entities must explain why they are registering

Legal entities created outside the Union and legal arrangements administered outside it must state why they are registering. The options follow the AMLR’s triggers: entering into a business relationship with an EU obliged entity, acquiring real estate in the Union, acquiring motor vehicles, watercraft or aircraft above the thresholds of Article 67(1)(c) AMLR in an occasional transaction, or being awarded a public contract or concession. Supporting documents and a description must be uploaded.

The legal form of a non-EU entity is chosen from at least “Company”, “Foundation” and “Other”. The classification is coarse, but the foreign vehicles often used to hold European property, yachts or aircraft at a distance from their real owners will now appear in the registers with a documented reason for being there.

Nominees move into the open

A separate article covers nominees. Registers will record the identity of nominee shareholders and nominee directors, whether natural or legal persons, the date the nominee arrangement began, whether it rests on a formal contract or an informal agreement, and a description of its nature. The nominator must be identified as well and, where the nominator is a legal person, so must its own beneficial owners.

Nominee arrangements remain one of the simplest ways to separate the visible owner of a company from the person who controls and benefits from it. Requiring both sides of the arrangement to be declared, along with its legal basis, makes that separation much harder to maintain quietly in the register.

When no beneficial owner can be found

A registrant that cannot identify a beneficial owner must choose a justification from a defined list. Either no beneficial owner exists (ownership is dispersed, the entity by definition has no legal owners and no one controls it, the beneficial owner of the arrangement has died, or that beneficial owner is an unborn descendant), or a beneficial owner could not be determined after exhausting all means of identification under Articles 51 to 57 AMLR.

For an obliged entity relying on the register, “none exists” and “could not be determined” are very different risk signals. A structured justification keeps that difference visible instead of leaving it in a free-text field.

The checklist: incomplete submissions are rejected

Article 5 lists the minimum elements without which a register may not accept a submission. For each beneficial owner, the full personal data set and the data on the nature and extent of the beneficial interest must be present. For legal entities, the register needs the basic data, the ownership and control structure where more than one entity or arrangement is involved and, for companies, the European Unique Identifier where available. Legal arrangements must provide their basic data and, for multi-layered structures, the structure description.

Submissions that miss any minimum requirement should not be accepted. Part of the data-quality burden therefore moves from later discrepancy reporting to the moment of filing, and the common formats allow registers to run many of those checks automatically.

Reuse of existing data and the transition

To avoid duplication, registers must reuse data already held in or reported to another register, provided it can be displayed in full compliance with the AMLR and the Regulation, or request it in the format already established there. This applies to personal data, entity data, arrangement data and nominee data alike, and registers may show users where such data came from.

Registrations made before 10 July 2027 are not immediately affected. Member States may, however, require any update to an existing entry to follow the new formats, and registers may take the transition into account when handling discrepancy reports on entries not yet updated. The General Data Protection Regulation applies to the processing, and the European Data Protection Supervisor gave its opinion on the draft on 14 January 2026.

What obliged entities and registrants should prepare

For entities that report to the registers, preparation should start well before July 2027. Corporate service providers, fund administrators, trustees and in-house legal teams should check whether their records hold every data point at the required level of detail, including full names, identity document details, exact ownership percentages, the specific nature of control and the start date of each beneficial interest. Groups with layered structures will need organisational charts that meet Annex I, and trustees will need deeds, addenda and the settlement details the Regulation asks for.

Banks, investment firms and other obliged entities are affected too. Under the AMLR they consult the registers as part of customer due diligence and report discrepancies. Standardised entries will make discrepancies easier to spot, and harder to explain when a customer file holds less or different information than the register. In Luxembourg, the Registre des bénéficiaires effectifs and the Registre des fiducies et des trusts will have to align their filing interfaces with the new formats.

Who counts as a beneficial owner remains a question for the AMLR. What the Implementing Regulation settles is how precisely that person, their interest and the structure behind them must be described, and registers with incomplete or inconsistent data will now have a common standard to measure themselves against.

Dive deeper

• EUR-LEX ¦ Commission Implementing Regulation (EU) 2026/2354 of 16 October 2026 on formats for submitting beneficial ownership information ¦ Link