Implementing Regulation on the format for the submission of beneficial ownership information to the central registers

Good evening, please find attached suggestions that based on experience in dealing with Cyprus Beneficial Ownership Registry and Registrar o Companies of the Republic of Cyprus as responsible local authority for the named central register (for private companies).

Dun & Bradstreet welcomes the European Commissions initiative to standardize beneficial ownership (BO) data formats across the EU. These measures are essential to improving AML/CFT effectiveness, enhancing transparency, and enabling cross-border interoperability. Our recommendations focus on ensuring accuracy, usability, and operational resilience while supporting innovation and compliance.

We support the Commissions objective of improving the clarity, usability, and interoperability of beneficial ownership (BO) information submitted to central registers. However, we set out below our observations regarding the mandatory visual representation requirement set out in the proposed Implementing Regulation (Articles 2(1)(i), 3(l), and Annex I) which could be considered as exceeding the requirements of MLD6…

December 23, 2025 By electronic submission Wolfsberg Group Response: Draft implementing regulation formats for the submission of beneficial ownership information to central registers The Wolfsberg Group welcomes the opportunity to comment on the EU Commissions draft implementing regulation on formats for submitting beneficial ownership information to central registers (the Regulation).

CIFA welcomes the Commissions objective to harmonise the submission formats for beneficial ownership (BO) information to enhance the interoperability of central registers across the EU, as mandated by Article 10(6) of Directive (EU) 2024/1640.

The Draft Implementing Regulation (hereinafter: IR) introduces important measures to enhance transparency in a non-bureaucratic manner, particularly through the obligation to re-use existing register data. However, several provisions should be adjusted to ensure proportionality, data minimisation, and administrative feasibility. Further details are provided in the attached file. I.

DT4C welcomes the Commissions initiative to harmonise the formats and data fields for beneficial ownership (BO) information across the EU and fully supports the objective of improving transparency, traceability and data quality for AML/CFT purposes.

Transparency International, together with our Brussels office Transparency International EU, are pleased to submit feedback on the draft Implementing Regulation on the formats for the submission of beneficial ownership information to the Member States central registers.

Privacy First (https://privacyfirst.nl/en/) is a Dutch non-profit organisation that has financial privacy as one of its focus areas. Privacy is not just about keeping things to yourself. It is also about treating personal data, such as financial personal data, with care.

I think it would be good to include two more sections: Article 1 format for the presentation of data on beneficial owners: 3. (g) For beneficial ownership by control (direct or indirect) and for beneficial ownership by ownership (direct or indirect), and whenever possible, a brief outline (in *.anb format) of how that person becomes the beneficial owner of the legal entity could be included.

see Annex The Federal Bar Association is the umbrella organisation for legal self-government. It represents the interests of the 28 bar associations and thus of the entire legal profession in the Federal Republic of Germany. I. Publication of comprehensive information on beneficial owners raises fundamental concerns.

Filed in German · English published by the European Commission

Assogestioni welcomes the opportunity to provide feedback on the European Commissions draft implementing regulation on formats for submitting beneficial ownership information. The comments below focus on specific aspects of the proposal that are particularly relevant for ensuring consistency with the forthcoming AML/CFT technical framework and for facilitating proportionate and efficient implementation. 1.

The Royal Netherlands Institute of Chartered Accountants (NBA) appreciates the opportunity to respond to the consultation on the draft Implementing Regulation (draft IR) on formats for submitting beneficial ownership information. The NBA is the professional body for accountants and auditors in the Netherlands.

This initiative will set out the formats to be used to submit the beneficial ownership information referred to in Article 62 of Regulation (EU) 2024/1624 to the central registers. The concept of beneficial ownership was introduced to increase the transparency of complex corporate structures in the fight against money laundering and terrorist financing.

Filed in Italian · English published by the European Commission

1. As a loose coalition of European Non for Profit Organisations (NPOs) including associations and public benefit foundations working on the impact of AML/CFT policies on the non-profit sector, we welcome the opportunity contribute to the consultation on formats for the submission of beneficial ownership information to central registers. 2.

AFG welcomes the opportunity to submit comments to the European Commission on its draft implementing regulation concerning the formats for communicating information on beneficial owners under European Directive 2024/1640. Our attention is focused more specifically on two points: 1.

Bloomberg welcomes the opportunity to provide comments on the European Commissions draft Implementing Regulation concerning the formats and technical specifications for submitting beneficial ownership (BO) information to central registers under AMLD6.

The proposed implementing regulation pursues the legitimate objective of improving the quality, consistency and comparability of data on beneficial owners (BOs) in central registers across the EU. This objective is broadly consistent with Regulation (EU) 2024/1624 and with the general interest in effectively combating money laundering.

Finance Denmark thanks you for the opportunity to submit comments to the consultation, and we support the purpose of the proposed rules. Comment: Art. 1(3)(e), following nature of control over the legal entity, appears to be missing the wording or legal arrangement. Alternatively, it could specify or legal arrangement when data on a beneficial owner is submitted under the option in point (b)(vii).

In accordance with the presented assumptions, a new requirement will be introduced, consisting in the obligation to present a visual form of ownership and control structure. ORLEN proposes that a template should be defined, providing for a minimum standard to ensure clarity and facilitate the comparability of published data.

EFAMA believes the following elements require due consideration in the draft implementing regulation (the Draft): 1. Multiple options (Art. 1(3)(b-c)) According to our understanding, the ability to choose multiple options to clarify the nature and extent of the beneficial interest and the beneficial owners (BO) for legal arrangements and legal entities is intended to provide flexibility when more than one option…

The proposed Implementing Regulation pursues the legitimate objective of increasing the quality, consistency and comparability of beneficial ownership (BOI) data in central registers across the EU. This objective is in principle in line with Regulation (EU) 2024/1624 and the general interest in effectively combating money laundering.

Filed in Slovak · English published by the European Commission

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the opportunity to comment on the draft Implementing Regulation defining formats for the submission of beneficial ownership information to central registers under the EUs 6th Anti-Money Laundering Directive (AMLD6).

The Federation of Business Information Services (FEBIS) welcomes the European Commissions initiative to establish common formats for the submission of mandatory beneficial ownership (BO) information to central registers, as mandated by Directive (EU) 2024/1640.

Open Ownership (https://www.openownership.org) welcomes the opportunity to respond to the European Commissions public consultation on the formats for the submission of beneficial ownership information to central registers.

Rynat Trading Ltd welcomes the initiative to harmonise the formats for submitting beneficial ownership (BO) information across the EU. The objective is sound and timely. However, certain elements of the Draft Implementing Regulation raise practical concerns that may hinder effective and consistent application by regulated entities.

Please find attached our submission on the proposed formats for the submission of beneficial ownership information. Foster Moore Ireland Limited is a software vendor that delivers government business registry solutions. We have delivered several Beneficial Ownership Registers globally and strongly recommend alignment with (or adoption of) the existing Beneficial Ownership Data Standards.