Brussels sets standard formats for beneficial ownership registers from 2027

The European Commission has fixed the standard formats and a minimum-data checklist that companies, trusts and nominee arrangements must use when filing beneficial ownership information with national central registers. Commission Implementing Regulation (EU) 2026/2354 of 16 October 2026 was published in the Official Journal of the European Union on 22 October 2026 and applies from 10 July 2027. From that date, registries may accept a submission only where every element on the checklist is present.

The regulation is adopted under Article 10(6) of Directive (EU) 2024/1640, the sixth anti-money-laundering directive, which requires Member States to set up central registers of beneficial owners. Regulation (EU) 2024/1624 determines what information must be reported to those registers; the new implementing act supplies the machine-readable shape of that data. The Commission’s stated aims are clarity for reporting entities, consistent data quality across the Union and interoperability between registers.

The text carries European Economic Area relevance, runs to 12 pages and was signed in Brussels on 16 October 2026 by Commission President Ursula von der Leyen. It enters into force on the twentieth day after publication, on 11 November 2026, but its obligations bite only from 10 July 2027 — the date Regulation (EU) 2024/1624 itself becomes applicable. The European Data Protection Supervisor was consulted and delivered an opinion on 14 January 2026, and the Committee on the Prevention of Money Laundering and Terrorist Financing gave a favourable opinion.

Ten data points for every beneficial owner

Article 1 lays down the mandatory fields for natural persons, each with a prescribed technical format:

• first names and surnames in full;
• place and date of birth, the latter as yyyy-mm-dd under Annex II;
• residential address, structured per Annex III (street, city, postal code and country obligatory);
• country of residence and nationalities, drawn at least from the ISO 3166-1 alpha-3 list, with a “stateless” option;
• type, number and issuing country of the identity document.

The regulation also fixes how the nature of the interest is coded. For legal arrangements the roles are settlor, trustee, beneficiary, object of a power, default taker, protector or any other natural person exercising ultimate control. For legal entities they are founder, member of the management body in its management or supervisory function, beneficiary, or any other controlling person. Ownership percentages allow two decimal points, and control must be tagged to one of nine categories, including control through nominee arrangements.

Trusts, asset bands and the organisational chart

For legal arrangements, Article 3 requires an upload of the trust deed or equivalent, including addenda. Where no deed exists, a description must be filed covering the type of settlement — unilateral, written instrument signed by settlor and trustee, inter vivos, testamentary or notarial — the governing law, revocability, any reserved powers of the settlor, the protector’s duties and any excluded persons.

The value of assets held in the arrangement is reported in bands rather than figures:

• under EUR 1 000;
• EUR 1 000 to EUR 10 000;
• EUR 10 000 to EUR 100 000;
• EUR 100 000 to EUR 1 000 000;
• EUR 1 000 000 to EUR 10 000 000;
• EUR 10 000 000 to EUR 50 000 000;
• above EUR 50 000 000.

Where a structure contains more than one entity or arrangement, Annex I requires an organisational chart: names and registration numbers of every entity and arrangement, whether each is a nominator or nominee, the names of natural persons acting as nominees, and the nature and extent of ownership or control, direct or indirect.

Nominees, nominators and the acceptance checklist

Article 4 extends the formats to nominee shareholders and nominee directors, whether natural or legal persons, and to the nominators behind them, including the nominators’ own beneficial owners. Each arrangement must record its start date and be flagged as resting on a formal nominee contract or an informal nominee agreement.

Article 5 turns these rules into a gate. Registries may accept a filing only if it contains the beneficial owner’s personal data and the nature and extent of the interest; the legal entity’s basic data plus a structure description where relevant and, for companies, the EUID where available; or the legal arrangement’s basic data plus its structure description.

Where registries may reuse existing data

The regulation allows derogations: where the required data already sits in another register and can be shown to users in full compliance with Regulation (EU) 2024/1624, the registry must reuse it or request it in its established format. National unique personal identification numbers, tax identification numbers and the Legal Entity Identifier are excluded because their formats are already settled. Registrations made before 10 July 2027 are not immediately caught, though Member States may require updates to comply.

The practical effect falls on the gatekeepers. Banks and notaries running customer due diligence will see ownership chains expressed in a single European vocabulary, while registries gain a lawful ground to reject incomplete filings — and a common baseline for spotting discrepancies across borders.

Source: Official Journal of the European Union, L series, No 2026/2354, 22 October 2026, p. 1/12 (official reference: Commission Implementing Regulation (EU) 2026/2354; ELI: http://data.europa.eu/eli/reg_impl/2026/2354/oj).