What this is: An international movement toward transparency is driving governments to mandate disclosure of who ultimately owns or controls companies.
What this means: Companies must stay ahead of varying global regulations to avoid penalties, maintain credibility, and operate with confidence in a shifting compliance landscape.
Europe’s Leadership in Beneficial Ownership Reform
Over the past decade, corporate transparency has become a central issue in global discussions, with European nations leading the charge in implementing regulations to curb money laundering facilitated by anonymous corporate structures.
While European nations, including the EU, continue to navigate the delicate balance between full disclosure of corporate beneficial ownership and privacy protections of the individuals, significant progress has been achieved through the implementation of the 5th and 6th EU Anti-Money Laundering (AML) Directives.
Expanding Transparency: The US, Asia, and Emerging Global Standards
Discussions on corporate transparency have gained traction worldwide, particularly in the United States, where debates focus on a less stringent version of Europe’s regulations. Although the US has temporarily paused its reporting requirements, it is promising to see these conversations taking place among key stakeholders. Meanwhile, several Asian countries have introduced or drafted corporate transparency legislation in recent years, with efforts aimed at strengthening governance, improving financial disclosures, and aligning with international standards.
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Let’s explore how different countries are shaping and enforcing beneficial ownership laws and reporting requirements.
Comparing Global Approaches to Beneficial Ownership Reporting
| Country | Public or Private Beneficial Ownership Register | Threshold for Beneficial Ownership | Regulatory Authority | Types of Companies Required to Report | Compliance & Enforcement |
|---|---|---|---|---|---|
| USA | Private (FinCEN database) | 25% ownership or more – significant control | Financial Crimes Enforcement Network (FinCEN) | Only applies foreign companies registered in the US at this time. Reporting Requirements for US companies have been paused. | Strict penalties, including fines & imprisonment |
| Canada | Public Federal register and provincial registers vary (some public, some private). | 25% ownership or more – significant control | FINTRAC, Corporations Canada (CBCA), plus provincial regulators. | Federal (CBCA) and other provinces (BC, ON, MB, NB, NL, PE, SK, QC, NS); some exemptions exist. Applies to Corporations, partnerships and certain trusts | Fines up to $200,000, imprisonment up to six months, additional provincial penalties. |
| UK | Public (People with Significant Control Register) | More than 25% shares or voting rights | Companies House | All UK-incorporated companies, LLPs, SEs | Mandatory and continuous reporting, accessible to public |
| Norway | Private (Register of Beneficial Owners) | More than 25% ownership or control | Brønnøysund Register Centre | Limited companies, savings banks, housing cooperatives, foreign entities | Regulators & financial institutions have access Voluntary reporting phase from October 2024, mandatory reporting commences from July 31, 2025. |
| BVI | Private (Beneficial Ownership Secure Search System – BOSS) | 10% ownership or control | Registry of Corporate Affairs | All BVI Business Companies & Limited Partnerships | Strict filing deadlines, penalties for non-compliance |
| Singapore | Private (Register of Registrable Controllers) | More than 25% ownership or control | Accounting and Corporate Regulatory Authority (ACRA) | Companies, LLPs, foreign entities registered in Singapore | Access limited to regulators & financial institutions |
| Hong Kong | Private (Significant Controllers Register) | More than 25% ownership or control | Companies Registry | All Hong Kong-incorporated companies (except listed companies) | Companies must maintain records but no public access |
| Australia | Proposed Public Register | Threshold under review | AUSTRAC & Treasury | Expected to cover corporations, trusts, and partnerships | Expected mandatory reporting, but details still evolving |
| Ireland | Limited access (Central Register of Beneficial Ownership – RBO) | More than 25% ownership or control | Companies Registration Office (CRO) & RBO | All Irish-incorporated companies & industrial/provident societies | Mandatory reporting, accessible to designated persons & authorities. Access limited pursuant to Court of Justice of the European Union (CJEU) ruling |
| UAE | Private (UBO Register) | 25% ownership or significant control | Ministry of Economy & Licensing Authorities | All UAE-registered companies except government-owned & listed entities | Strict penalties, including fines up to AED 1,000,000 |
Transparency as a Competitive Imperative for Global Businesses
Corporate transparency continues to evolve as governments and businesses worldwide strengthen regulations to combat financial crime, enhance accountability, and build investor confidence. Emerging technologies, such as AI and blockchain, are also shaping the future of corporate governance, making compliance more efficient and data driven. As transparency becomes a cornerstone of ethical business practices, companies must adapt to evolving regulations to maintain trust and competitiveness in the global market. This is an interesting space to watch out for in the coming years.
This article is provided for informational purposes only and should not be considered, or relied upon, as legal advice.
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