UBO Verification Under AMLA’s RTS: Why the Central Register Is Not Enough

On 1 October 2026, the EU’s Anti-Money Laundering Authority (AMLA) published its regulatory technical standards (RTS) on customer due diligence, the first EU-wide rulebook for verifying ultimate beneficial owners (UBOs). 

The headline is that the central beneficial ownership register is not enough. Obliged entities need at least two sources: one that identifies the beneficial owner, and a second, independent one that verifies the first source. You also must collect data on every intermediate entity in the ownership chain, including legal form, jurisdiction, share classes and voting rights, and collect extra information for higher-risk customers.

This guide covers what the RTS treats as an “independent, reliable” source and what to do when you can’t access the central register. It also shows how company register shareholder data lets you build the story of an entity and ends with an index comparing UBO and shareholder data access across ten EU jurisdictions.

Read Kyckr’s complete guide to what the RTS says about KYB data, documents and sources.

The difference between identifying and verifying a beneficial owner

First, Article 19(2) distinguishes between identifying and verifying a beneficial owner of a legal entity.

• Identifying a beneficial owner means finding an independent, reliable source that tells you who owns, controls or benefits from a legal entity.

• Verifying a beneficial owner means confirming that information is correct by using another independent, reliable source. This means that, if you find that the central register is incorrect, you can fulfil your obligation to file a discrepancy report.

In short, at the very least, EU law requires two sources.

What sources do you need to pull from? 

These are the standard “reasonable” measures that must be taken, according to Article 10.

• Public registers “other than the central register” (that is, the beneficial ownership register), like business, residence, tax, passport, and property registers

• Third-party sources like “reputable” data service providers, credit or financial institutions, obliged entities within the group, or documents from the legal entity that lists the UBO’s name and where their identity has been “certified by persons that are authorised for document certification purposes”.

What counts as an “independent, reliable” source

Article 8 covers every source you use, whether for simplified, standard or enhanced due diligence: you "shall" take risk-sensitive measures to ensure your sources are "independent" and "reliable". This means asking:

• Is it credible?

• Is it official and independent?

• Is it up to date?

• Has it been verified, or does it match other sources?

• How easy is it to forge?

The 2-step process to ‘identify’ and ‘verify’ the beneficial owner 

According to Article 19, you "may” identify the beneficial owner, or senior managing official, in low-risk situations, using one of the following sources:

• Central register

• Business or company register

• Customer information

• Public information from a “reliable, independent open source”

Then, verify the identity using either the company or business register, customer information, or publicly available information from a “reliable, independent open source”, so long as the source in question wasn’t used to identify them.

For example, you could identify the beneficial owner using the central register and verify that information using the business register.

What happens if you can’t access the central register? 

The regulatory technical standards provide multiple fallback options if the central register is inaccessible – and many are.

Since the Sovim ruling in November 2022, access to EU beneficial ownership registers has been fragmented, and, despite the AMLD6 requiring member states to provide access to persons with a legitimate interest, individual registers have been slow to build workable, operational routes.

If you can’t access the central register, you may identify the beneficial owner from other sources, including the customer – for example, a central register-certified UBO extract – and verify that information by consulting another source, like the relevant member state’s company register.

Ensure you keep a record of your decision to do so on the customer’s file; it may be useful later if an auditor inquires as to why you didn’t consult the central register.

What company registers can (and can’t) tell you about the beneficial owner

Company registers don’t generally hold beneficial ownership information, but many hold shareholder information, which you can use to ‘build the story’ of a legal entity. You start by working out which shareholder, be they a corporate or natural person, holds the largest number of shares or voting rights as a total percentage, and follow the ownership chain, through (if relevant), any intermediate ownership layers, until it reaches the beneficial owner.

For example, you request a beneficial ownership declaration from the customer because you can’t access the central register. The difficulty is that the beneficial ownership disclosure, while certified as “official” by the central register, has not been verified by the registrar, as is the case with most UBO registers. Moreover, the beneficial owner of the legal entity is not registered in the same jurisdiction as the representative applying for a bank account. You need to ‘build the story’ of the legal entity and work out the ownership and control chain that leads to the beneficial owner.

To verify it, you rely on shareholder information you find in the company register on which the legal entity is registered. You can normally find these in company extracts, but every register differs. In Cyprus, you can find this in the HE32 form (annual return), while Spain publishes it in the incorporation deed, also called the escritura de constitución.

Doing this manually takes hours, sometimes days, leading to higher rates of customer dissatisfaction, attrition, and slower onboarding. Kyckr’s ownership discovery tool uses the underlying shareholding data that companies are required to file at certain national registries to automatically calculate ultimate ownership.

How does UBO verification change with risk, according to the AMLA?

According to Article 11, these must be risk-sensitive measures, not blanket standards to apply to every situation. In other words, the higher risk the customer poses, the more these measures apply. Therefore, you must have “regard to elements that may increase complexity”, meaning:

• The number of ownership and control layers between the customer and the beneficial owner.

• The presence of legal arrangements, like trusts.

• If any of those entities within the structure are present in higher-risk jurisdictions.

• The use of nominee directors or shareholders.

In high-risk cases (Articles 21 to 23), you need reputation checks, details of the owner’s business associates, evidence of their source of funds and wealth, and an expert view on why a complex structure exists.

What data do you need to collect on the intermediate ownership layers?

Article 11 says that once you’ve understood whether “more than one legal entity or legal arrangement” is involved, you need data on all of them:

• Legal forms.

• Existence of nominee shareholders or directors.

• Jurisdictions of incorporation or registration. If trusts are involved, the “jurisdiction of its governing law”.

• Shares: the total, subdivision – by class or type of shares – and voting rights as a percentage of the total.

• If one of the entities in the middle of the chain is listed, you need to record which regulated market, as well as the number and percentage of shares.

An index of the top EU jurisdictions by accessibility of UBO and shareholder data

Want to learn more? Read the Kyckr guide to every EU beneficial ownership register, by accessibility.

Kyckr provides one place to access every company register

Kyckr is the global business register, a single access point to a live network of company registers in over 100 countries. Kyckr lets you retrieve data and documents in real time from company registers, time- and date-stamped at the point of retrieval.

Using Kyckr’s tool, Ownership Discovery, you can automatically calculate the beneficial owner using shareholder data retrieved from company registers, enabling faster verification of beneficial owners and faster onboarding. Book a demo to learn more.