Ultimate beneficial owner (UBO)
An ultimate beneficial owner (UBO) is the natural person who ultimately owns or controls a company, directly or through other companies, trusts or arrangements. Under EU anti-money laundering rules, anyone with an ownership interest above the 25% threshold counts, and so does anyone who controls the company by other means.
Who counts as a UBO
A UBO is always a person, never a company. If a company is owned by another company, you keep following the chain until you reach the people at the top.There are two routes to being a UBO. The first is ownership: under the current EU AML Directive, holding more than 25% of the shares, voting rights or ownership interest. From 10 July 2027, the EU AML Regulation sets the line at 25% or more, and lets the Commission set a lower threshold, of up to 15%, for categories of company it considers higher risk.The second is control by other means, whatever the shareholding: the right to appoint or remove most of the board, a veto over key decisions, or an agreement that gives someone the final say.If nobody qualifies by either route, the company records its senior managing official, usually the CEO, in the UBO field. That's a fallback for the register, not a finding that the CEO owns the company.For trusts, the settlor, the trustees, any protector and the beneficiaries are all treated as beneficial owners.
How ownership is calculated through layers
Indirect ownership is calculated by multiplying the percentages along each chain, then adding the chains together. Here's an operating company, OpCo, owned through two holding companies:| Person | Route to OpCo | Calculation | Effective interest | UBO by ownership? |
|---|---|---|---|---|
| Anna | Owns 60% of Holding A, which owns 50% of OpCo | 60% × 50% | 30% | Yes |
| Ben | Owns 100% of Holding B (20% of OpCo), plus 10% of OpCo directly | 100% × 20% + 10% | 30% | Yes |
| Carla | Owns 40% of Holding A | 40% × 50% | 20% | No, unless she controls OpCo another way |
UBO vs shareholder vs UK PSC
| Shareholder | UBO (EU) | Person with significant control (UK) | |
|---|---|---|---|
| Can be a company | Yes | No, always a natural person | Yes, as a relevant legal entity |
| Ownership threshold | Any holding | Above 25% (25% or more from July 2027) | More than 25% |
| Includes control without shares | No | Yes | Yes |
| Where it's recorded | Share register | National UBO register | Companies House PSC register |
UBO registers in the EU
Every EU member state keeps a central register of beneficial owners. Until 2022, several made them fully public. On 22 November 2022, in joined cases C-37/20 and C-601/20, the EU Court of Justice ruled that unrestricted public access breached the right to privacy.Since then, access has narrowed. Authorities and obliged entities, such as an account provider running its checks, still have access, and in most countries other people need to show a legitimate interest. [CONFIRM: current access rules in Finland and the AMLD6 legitimate-interest framework, if the entry describes them in more detail.]What an account provider asks for
When you open a business account, the provider identifies and verifies every UBO as part of its know your business checks. Expect to provide:- an ID document and proof of address for each UBO
- a group structure chart that goes all the way up to the natural persons, with percentages at each level
- an extract from the relevant UBO register
- for trusts, the trust deed and the details of settlor, trustees and beneficiaries
FAQ
A company always has someone at the top, but no one may cross the threshold or control it by other means. In that case, its senior managing official is recorded instead.
No. A UBO is always a natural person. When a trust sits in the ownership chain, the people behind it (settlor, trustees, protector and beneficiaries) are treated as beneficial owners, as covered for family office structures.
No. A UBO can be a passive investor with no role in running the company. Directors only count as UBOs if they also own or control it.
Related terms and sources
Know your business (KYB) · Source of funds vs source of wealth · Legal Entity Identifier · Qualifying holding · High-risk third country · Debanking · Browse the full glossary
Last reviewed October 21, 2026Disclaimer
This publication is provided for general information purposes and does not constitute legal, tax, or other professional advice from Narvi Payments Oy Ab or its affiliates, and it is not intended as a substitute for obtaining advice from a financial advisor or any other professional.
This publication is provided for general information purposes and does not constitute legal, tax, or other professional advice from Narvi Payments Oy Ab or its affiliates, and it is not intended as a substitute for obtaining advice from a financial advisor or any other professional.
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