Find out what counts as beneficial ownership information, what businesses may need to report in the US, Europe, and the APAC region, and how recent changes to US reporting obligations could affect your business.
Since the leaks in the Panama Papers revealed a vast network of shell companies used to obscure illicit funds, there has been a coordinated international effort to record the true identity of company beneficial owners—those who ultimately own or operate a business.
These revelations underscored the gaps in global corporate transparency and prompted updates in legislation to combat money laundering, terrorist financing, and related financial crimes. As such, jurisdictions around the world have passed acts to mandate companies to provide information on their UBOs. This is also partly driven by Financial Action Task Force (FATF) international standards to increase corporate transparency.
While there are similarities between jurisdictions’ requirements, they do vary and can change, as evidenced by the significant recent shift in beneficial ownership reporting requirements in the USA.
In this article, we’ll be taking a closer look at the reporting procedures that affect the USA, most of Europe, and APAC, why they matter, who is exempt from reporting in 2025, and what penalties your business could face for non-compliance.
Beneficial ownership information (BOI) refers to details on who ultimately operates or owns a company. In other words, it is information on UBO identity.
Some beneficial owners may try to hide the fact they are beneficial owners using means like nominees, trusts, or legal entities such as shell companies. This could be due to a desire to evade taxes, avoid sanctions, or even conceal illegal activity, such as links to organized crime or corruption.
As a result, BOI is crucial for helping businesses understand who they are truly doing business with so they can act accordingly.
Suggested read: UBO: Understanding the Ultimate Beneficial Owner
In the USA, for example, the Financial Crimes Enforcement Network (FinCEN) defines a beneficial owner as someone who:
The information that needs to be provided as part of BOI reporting also varies around the world. Companies required to report BOI in the USA, for instance, must disclose:
In Europe, the procedure and the list of required information to be disclosed are similar. You can find the UBO disclosure requirements for the EU outlined in this document.
Across APAC, understandings of UBOs are similar due to the impact of FATF guidance. However, there are variations in terminology. For example, UBOs are known as Beneficial Owners in China and Japan, but as Significant Controllers in Hong Kong and Registrable Controllers in Singapore.
Following FATF guidance urging countries to establish open beneficial ownership registries, many regulatory bodies around the world require accurate and up-to-date records on the beneficial ownership of legal persons.
BOI reporting is a global initiative and many jurisdictions around the world have now implemented or planned beneficial ownership transparency reforms, with mandatory registers on beneficial owners.
As such, it is now a legal requirement to report BOI in 97 countries around the world; this requirement is being actively implemented or planned in 65 further countries. However, who exactly has to report BOI varies depending on the jurisdiction and may change over time.
For example, in March 2025, the US FinCEN removed the requirement for US companies to file beneficial ownership information reports (BOIRs) or for US persons to be named in them. Foreign companies, however, are still required to report BOI in the US.
This act was originally introduced to combat illicit activities like money laundering, fraud, and terrorist financing by increasing the company ownership transparency. While BOI filing obligations were introduced for many entities in 2022, in March 2025, FinCEN issued an interim final rule removing any reporting obligations and enforcement actions for entities formed under US state or tribal law. It also removes obligations for US persons considered UBOs.
In the EU, member states were required to establish public UBO registers by January 2020, containing details such as the owner’s name, date of birth, nationality, and type of ownership. However, a 2022 European Court of Justice ruling restricted public access, citing privacy concerns. It is also worth mentioning that access is now limited to authorities and those with a legitimate interest like journalists and NGOs.
The new EU AML Package strengthens UBO register requirements and ensures legitimate stakeholders—like journalists, civil society, and regulators—have free and immediate access. It also clarifies that both direct and indirect ownership, as well as control through other means, must be considered when identifying a beneficial owner. While the standard threshold remains 25% ownership or voting rights, member states may apply lower thresholds for higher-risk sectors.
In the APAC region, many countries align with FATF guidelines for BOI reporting. However, there is significant variety in levels of enforcement and transparency. While Singapore, for example, mandates companies to file Register of Registrable Controllers information and Hong Kong requires disclosure through the Significant Controllers Register, in Australia, there is no public UBO register.
As of March 26, 2025, all existing foreign companies operating in the USA are required to report their BOI within 30 days (i.e., a deadline of April 25, 2025). New foreign companies operating in the USA will also need to file a BOI report within 30 days of registration, unless exempt. After the first BOI report, companies in the US only need to report again if the reported information changes or is incorrect.
Companies need to file updated reports within 30 days if there is a change in company details (e.g., name or address), personal information (e.g., name, address, or ID), or a change in beneficial ownership.
If an error or inaccuracy is discovered, companies must also file a corrected BOI report within 30 days of the discovery.
EU member states require companies to file BOI with national registers, typically within a short period after company formation or registration.
Deadlines vary by country but generally require:
For trusts and similar arrangements, filing deadlines often follow specific national rules, with some countries imposing strict deadlines.
BOI reporting requirements across APAC reflect the diversity of the region’s legal frameworks. Some countries, like South Korea, do not yet have a centralized register and expect entities to maintain their own UBO records.
Deadlines and compliance timelines across APAC vary but often include:
China’s 2024 UBO reporting rule provides a one-year grace period, mandating entities to comply by November 2025.
This includes the details of the reporting company and the details of each beneficial owner.
Information required for reporting companies:
Information required for each beneficial owner and company applicant:
– i) This allows you to prepare and file the BOIR in your internet browser
– ii) You can download the form PDF by selecting Prepare BOIR and then upload it when it is complete
| Do Not | Do |
| Assume you don’t need to file a BOIR | Check whether you need to file a BOIR, even if you believe you are exempt |
| Upload an image of an invalid ID | Check the requirements for what ID is accepted |
| File late | Monitor when you need to file |
| Make assumptions about technical terms | Check with an expert on technical terms, e.g., who qualifies as a beneficial owner |
You may use or request a FinCEN ID for beneficial owners if available.
The same form is required for all types of companies. For example, an LLC BOI report is the same report as for an LLP. Full filing instructions are available via FinCEN’s Beneficial Ownership Information Report.
For official step-by-step guides to filing BOI reports in Europe, you should consult the national company registers or government portals of each EU member state. Here is an example of an official guide from Luxembourg, which is representative of the process in many EU jurisdictions:
In other EU countries, the process is similar. Here are the official links:
Processes vary widely across APAC, which complicates the possibility of a step-by-step guide. However, below are the official links for BOI reporting details in countries in the APAC region that have UBO registers:
Following the update to BOI reporting obligations in March 2025, no US company is required to file a BOIR. Only non-US companies operating in the US must file a BOIR.
However, the following companies are exempt from filing BOIRs in the US, even if they are foreign companies:
1. Publicly traded companies on US stock exchanges
2. Banks and credit unions regulated by federal or state banking authorities
3. State-registered insurance companies
4. Businesses with more than 20 full-time employees, $5 million in revenue, and a physical US presence
5. Nonprofit organizations, including charities and religious groups
6. Wholly owned subsidiaries of exempt public companies
7. Entities predating January 1, 2020, with no active operations, assets, or ownership changes
8. Investment companies regulated under the Investment Company Act of 1940
9. SEC-registered investment advisors
10. Pooled investment vehicles
11. US federal, state, and tribal government entities
12. Utilities regulated by public commissions
13. Entities providing services exclusively to exempt organizations like charities
14. State-regulated accounting firms
15. Entities registered under the Securities Exchange Act, including broker-dealers
16. Clearing agencies regulated by the SEC
17. Entities designated systemically important by the Financial Stability Oversight Council
18. Churches and other religious institutions recognized under federal tax law
19. Certain pension funds and retirement accounts
20. Political organizations regulated by the Federal Election Commission
21. Small government entities, such as municipal boards and agencies
22. Payment processors
23. Trusts already reporting under other federal programs
Exempt companies must be able to prove they are exempt.
In Europe, certain entities are exempt from reporting BOI to national registers under the EU Anti-Money Laundering (AML) framework and related national laws. The key exemptions include:
Companies whose securities are admitted to trading on a regulated market subject to EU disclosure requirements or equivalent international standards are exempt from BOI reporting. This exemption applies provided that:
Instead of reporting BOI, listed companies must declare the name of the regulated market and confirm their exemption status. Subsidiaries wholly owned (100%) by such listed companies are often also exempt, though implementation varies by country. For example, the Netherlands and Germany apply this exemption to subsidiaries under certain conditions, while Belgium relies on tax authority opinions for exemptions of subsidiaries.
The EU AML package recognizes the complexity of investment funds’ legal forms and allows for specific approaches consistent with their purpose and function. While investment funds must disclose beneficial ownership, the identification approach may vary depending on whether they are legal entities or legal arrangements without legal personality.
Entities already subject to robust transparency and disclosure regimes under EU law or equivalent international standards may be exempted from BOI reporting to avoid duplication.
If no natural person meets the ownership or control threshold (usually 25%, or lower thresholds for high-risk sectors), some jurisdictions allow reporting the senior managing official(s) instead of a beneficial owner.
Exemptions vary from jurisdiction to jurisdiction across APAC, but may apply to:
It is worth checking whether your business qualifies for exemption.
Penalties for non-compliance with BOI reporting obligations vary by jurisdiction and can be severe. Depending on the nature and intent of the violation, consequences may range from minor fines imposed on companies to criminal charges, including imprisonment. Here’s how non-compliance is penalized in the US, Europe, and APAC.
US
While the US Treasury Department announced in March 2025 that there would be no penalties for non-compliance among US citizens, US companies, or US UBOs, penalties for non-compliance with BOI reporting obligations can be severe in the US.
Non-domestic companies who fail to comply with the reporting requirements of the Corporate Transparency Act (CTA) could face penalties of up to $500 for each day of continuing violation. Criminal penalties include a maximum of two years imprisonment and a fine of $10,000.
Europe
In some European countries, penalties for failing to submit or update information in the UBO register have been revised and somewhat softened, though they remain enforceable. For example, in Cyprus, fines may begin at approximately €100 for the first day following a missed deadline, increasing by €50 per day up to a maximum of €5,000—a reduction from previously higher penalties.
In Luxembourg, non-compliance can still result in significant fines, ranging from €1,250 to €1,250,000, applicable to both legal entities and beneficial owners.
APAC
Penalties for non-compliance with BOI reporting obligations vary across the APAC region and may depend on the severity of the violation. For example, BOI reporting violations in Hong Kong can lead to fines of HKD 25,000 and daily fines of HKD 700 for continued violations.
Similarly, failure to comply in Singapore may lead to fines that escalate on continuation. Filing false information could even lead to imprisonment.
Suggested read: KYC Verification: Full Guide to Know Your Customer Compliance
As BOI reporting is a legal requirement in most major markets around the world, it is essential to be transparent, accurate, and helped by expert advice in compliance, regardless of the jurisdiction.
It is not only important to identify all UBOs at the time of registration but to also report updates if the company’s structure changes (e.g., in the case of board changes or share transfers). To make sure companies have the required information for compliance, it is important to have a regularly updated internal register of UBOs (including their full legal names, dates of birth, addresses, and shares of control), as well as a copy of their ID. Best practices include internal governance that identifies UBOs at the time of company registration and during any structural changes.
It is also crucial to stay informed and rely on expert legal advice instead of making assumptions that all BOI reporting policies will be the same. Just because a company may be exempt from reporting in the USA, it does not mean it will be in Germany. Additional laws such as data protection and privacy laws may also restrict how data is shared.
Designating a compliance officer and conducting regular AML/KYC training for relevant personnel is essential for ensuring regulatory readiness.
Suggested read: Anti-Money Laundering (AML) Policy: Step-by-Step Guide (with Template)
As more countries around the world implement and plan BOI reporting obligations, businesses must make sure they truly know and accurately report their company structures if they want to continue legal operation and maintain their reputations. With regulations evolving, it becomes necessary to use a streamlined, secure, and scalable solution.In an ever more complex regulatory landscape, Sumsub’s Ultimate Beneficial Ownership verification simplifies BOI reporting by helping businesses identify and verify UBOs while staying compliant with globally shifting regulations. It not only makes compliance easier but also helps build trust among business partners and regulators alike.
Beneficial ownership information (BOI) reporting refers to the disclosure of information about who ultimately owns or controls a company. It is a legal requirement for many types of entities in a considerable number of jurisdictions around the world.
Unless they qualify for one of the 23 specific exemptions listed in this article, all foreign entities registered for business in the US must file a beneficial ownership information form called a BOIR.
The deadlines for BOI reporting vary from jurisdiction to jurisdiction. In the US, a report must be filed within 30 days of entity registration or formation, or within 30 days of detection whenever an update or correction is needed. For example, a reporting entity that has not filed a BOI report following the shift in policy on March 26, 2025, has until April 25, 2025, to file a BOI report.
Penalties for non-compliance vary from jurisdiction to jurisdiction. In the US, a failure to file a BOI report may lead to civil penalties (e.g., $500 per day overdue) or criminal penalties (e.g., up to two years of imprisonment).
Yes, there are exemptions to BOI reporting requirements in jurisdictions around the world. In the US, 23 types of entities are exempt, which are listed earlier in this article. Further to this, only non-US companies need to file for a BOI report in the US.
