Ultimate Beneficial Owner Register: Who Files, Who Sees It

A beneficial owner register records the individuals who ultimately own or control a company.

There is no such thing as "the" register: each country keeps its own, and only one of the six below lets anyone read it.

The short answer

Three things to hold on to:

• The threshold is almost always more than 25%.
• Filing and public access are separate questions.
• Four of these six regimes changed between November 2025 and November 2026.

Nov 18, 2025United Kingdom: PSCs must verify their identity

Jan 2026Estonia: access reopens under a tiered model

Aug 14, 2026United States: the BOI exemption for US companies becomes final

Nov 10, 2026Ireland: legitimate interest applications, answer within 12 working days

1. Nov 18, 2025United Kingdom: PSCs must verify their identity
2. Jan 2026Estonia: access reopens under a tiered model
3. Aug 14, 2026United States: the BOI exemption for US companies becomes final
4. Nov 10, 2026Ireland: legitimate interest applications, answer within 12 working days

What an ultimate beneficial owner is

The ultimate beneficial owner, or UBO, is the individual at the end of the ownership chain. The UK guidance says it in plain words: a person with significant control "is someone who owns or controls your company. They're sometimes called 'beneficial owners'."

Two tests recur in every regime:

• Ownership. More than 25% of the shares or of the voting rights.
• Control. The power to steer the company by another route, such as appointing or removing most of its directors.

Provider guides trace the 25% figure to the FATF standard. Each country then writes its own version, which is why the details below differ.

One consequence follows from the definition. The register looks for the individual behind the holder, so placing shares with a nominee does not remove you from it.

Three questions, not one

Most guides ask "is there a UBO register?" That hides three different questions:

1. Does the company keep its own register? A document held at the office, shown on demand.
2. Is there a central register? A filing with a state body.
3. Can the public read it? Free search, application, or no access at all.

1. Kept by the company

• Singapore: the RORC
• Hong Kong: the SCR, at the office

2. Filed with a central register

• United Kingdom: Companies House
• Ireland: the RBO
• Estonia: e-Business Register
• Singapore: ACRA, within 2 business days

3. Readable by the public

• United Kingdom: the PSC entry, free

Outside the picture

• Delaware and Wyoming: no report for US companies since August 2026

Declaring your ownership and being publicly readable are two different things. Five of these six jurisdictions make you declare. One publishes the result.

The sections below answer the three questions for each place, from the seat of the person being entered.

United Kingdom: the PSC register

The UK calls its beneficial owners people with significant control, or PSCs. Under the GOV.UK guidance, a PSC is usually anyone who:

• holds more than 25% of the shares or of the voting rights
• can appoint or remove the majority of the directors
• can influence or control the company, or a trust

The company reports its PSCs to Companies House at incorporation, then every time something changes.

Two points for a founder abroad:

• Refusal is a crime. "Refusing to provide PSC information is a criminal offence", and the company can restrict the shares or voting rights concerned.
• The filed record is the one that counts. The guidance was updated "in line with changes to company registers", so work from what Companies House holds.

Verification deadlines for existing PSCs depend on your situation, so check your own date with Companies House.

Access is the simplest of the six: anyone can read the PSC entry, free. Nationality and country of residence appear; the home address and day of birth do not. The entry is self-declared, a point covered in reading the PSC section on Companies House.

Ireland: the RBO, and what changes on November 10, 2026

Ireland runs a central Register of Beneficial Ownership, the RBO, on a portal separate from the company register. Our Irish guides give the filing rule:

• every company files its beneficial owners, meaning individuals holding more than 25%
• the filing is due within 5 months of incorporation
• owners without an Irish PPSN complete an extra identity verification form

Banks check the RBO during onboarding, so an unfiled entry blocks an account in practice.

Access went the other way. After the EU Court of Justice ruling of November 22, 2022, Ireland limited the register to designated persons from December 22, 2022.

New regulations, S.I. No. 406/2026, now create a formal application based on legitimate interest.

The amended regulation gives the right to inspect to "a person to whom a certificate is issued". Pinsent Masons reads it the same way: the register stays closed to the general public. For a founder, the change is narrower than it sounds:

• a future supplier or customer may now apply to see who is behind your company
• a curious stranger still may not

Estonia: tiered access since January 2026

Estonia was long described as fully open. That is out of date.

• 2025. Public access to beneficial owner data was restricted.
• January 2026. Access reopened under a tiered model.
• Today. General public access is no longer available.

The rest of the Estonian record stays unusually open, and we list what the Estonian register still shows for free in a separate guide.

The register's help page says a new legal entity submits its list of beneficial owners at establishment, on the e-Business Register portal or through a notary. A change needs no signature and no state fee. We did not verify the threshold in the act itself. EU rules on access also continue to move through 2026.

Singapore: two registers, neither public

Singapore has both layers. ACRA states the first one directly: "Since 31 March 2017, you must set up and maintain an RORC unless your business is exempted."

RORC stands for Register of Registrable Controllers. It applies to companies, foreign companies and LLPs. A controller is someone with:

• more than 25% of the shares, or shares carrying more than 25% of the voting rights
• for a company without share capital, a right to more than 25% of the capital or profits
• more than 25% of the members' voting rights
• the right to exercise, or the actual exercise of, significant influence or control

The clock is the tightest of the six.

Some entities are exempt, for example a public company listed on an approved Singapore exchange. An exempt entity must still declare its status.

On access, ACRA leaves no room for doubt:

• the central data "is not available to the public"
• "Shareholders who are not company officers cannot view your RORC."
• "Members of the public cannot view or buy your RORC information."

The paid Business Profile shows shareholders, which is a different list.

Hong Kong: a register kept at the office

Hong Kong has the first layer only. Since March 1, 2018, every company incorporated there must keep a Significant Controllers Register, the SCR.

• Where. At the registered office, or at another place in Hong Kong.
• Central filing. None. The SCR is not filed with the Companies Registry.
• Threshold. Direct or indirect holding of more than 25% of the issued shares or of the voting rights, among other conditions.
• Corporate shareholders. A legal entity above the threshold is entered too.

The company must also name at least one designated representative to assist law enforcement officers. That person is either:

1. a shareholder, director or employee who is an individual resident in Hong Kong
2. an accounting professional, a legal professional, or a licensed trust or company service provider

Access is limited to one group. The Companies Registry says the register "should be open for inspection by law enforcement officers upon demand". No public search exists.

United States: no register for Delaware and Wyoming companies

Most guides still describe the FinCEN report as a duty of every new US company. It is not.

• March 26, 2025. An interim rule exempted US companies.
• August 11, 2026. A final rule made the exemption permanent.
• August 14, 2026. The final rule took effect.

FinCEN's wording: "U.S. companies are exempt from BOI reporting requirements and therefore, are no longer required to file BOI reports."

What remains is narrow. Certain foreign companies registered to do business in the United States still report, and they do not have to report their US beneficial owners.

At state level, the formation filing in Delaware or Wyoming names neither members nor beneficial owners. A US company formed by a foreign founder therefore sits in no ownership register at all.

What you declare, by jurisdiction

Before you incorporate, settle four things:

1. Who passes the 25% line, directly or through another company.
2. Who controls the company without passing it.
3. Which identity documents each of those people can produce.
4. Who will update the entry when the cap table changes.

The summary