The European regulatory environment for beneficial ownership (BO) data has undergone fundamental shifts since the 2022 ruling of the Court of Justice of the European Union (CJEU) and subsequent adoption of the 6th anti-money laundering directive (AMLD6) and the AML Regulation (AMLR).
While public access to beneficial ownership registers has been significantly curtailed, regulatory expectations for obliged entities to identify and verify beneficial owners have increased, emphasizing the need for use of multiple, independent, and reliable data sources.
Against this backdrop, Moody’s ownership data has also become more important. As direct access to registers fragments and becomes risk- and status-dependent, obliged entities increasingly require integrated, cross-border, and methodologically robust ownership intelligence.
Moody’s solutions combine proprietary ownership calculations, multi-source data ingestion, and live registry access to help customers conduct their evolving anti-money laundering (AML) and counter-financing of terrorism (CFT) activities more efficiently.
The landscape of beneficial ownership (BO) data in the EU has changed markedly following the judgment of the CJEU on November 22, 2022, which invalidated the provision in the 5th Anti-Money Laundering Directive (AMLD5) that granted free, unrestricted public access to beneficial ownership registries.
In response, the European Union substantially recalibrated access rules in AMLD6 and the accompanying AMLR. Under the new framework, competent authorities and obliged entities retain full access to beneficial ownership information, while access for other parties is limited to cases where a legitimate interest can be demonstrated, subject to strict conditions.
Although EU member states are still in the process of fully transposing AMLD6 and implementing the supporting technical standards and procedural frameworks, many national registers of beneficial owners have already restricted or suspended public access. This evolving access environment has led to questions in the market about the availability and continuity of beneficial ownership data.
However, these developments do not diminish the value of integrated ownership intelligence solutions. As direct access to registers becomes more fragmented, jurisdiction-specific, and conditional, obliged entities may need to rely on consolidated, multi-source ownership data to meet their regulatory expectations. In this context, Moody’s ownership data — curated, enriched, and calculated across jurisdictions — can help play a role in supporting more effective execution of customer due diligence processes, developing ownership transparency, and automating compliance-related activities.
All EU member states are required under European AML law to maintain registries that record the beneficial ownership (BO) of legal entities. Companies and other legal entities must report who ultimately owns them and whether anyone controls them through means other than ownership.
This BO information differs from the shareholder details recorded in commercial registers, which reflect a company’s immediate legal owners. Unlike shareholders—who may be legal entities such as businesses or natural persons—beneficial owners must always be natural persons.
The EU beneficial ownership registers provide information on:
AMLR requires that registers begin collecting data on the ownership structure, including intermediary beneficial owners. While some registers have been collecting this for years, others are yet to define the format and the processes for this data.
Under the AMLR, art. 16, obliged entities are required to:
Additionally, obliged entities are required (AMLR, art. 19) to collect proof of registration or an excerpt from the register of beneficial owners whenever entering into a new business relationship with a legal entity. They can also use the information retrieved from the register of beneficial owners for the purposes of verifying the information on the beneficial owners in their due diligence procedures, although they are not allowed to rely on it.
This approach is in line with the multi-pronged approach prescribed by the Financial Action Task Force (FATF), which says beneficial ownership should not be identified or verified from a single source alone, but using multiple, independent sources of information that can be cross-checked to ensure the information is adequate, accurate, and up-to-date.
Following a period of public consultation, the European Banking Authority (EBA) has formally submitted advice to the European Commission and Draft Regulatory Technical Standards (RTS) for customer due diligence.
The EBA’s response is advisory: the actual drafting, adoption, and publication of the RTS will be done by the newly established EU Anti-Money Laundering Authority (AMLA) in consultation with the European Commission and is scheduled to be published by July 2026.
Based on the RTS, obtaining data and documents from independent and reliable sources is key so that obliged entities can be satisfied that they know who their customers are. Article 8 specifies that to determine if a source is reliable and independent, obliged entities should assess the following criteria:
The RTS (Art. 11) specifies that obliged entities should take risk-sensitive measures to obtain a description of the ownership and control structure, including the details of any intermediate legal entities or arrangements.
Moody’s solutions are designed to help customers navigate the RTS requirements for using independent and reliable sources in AML due diligence by combining robust data, rigorous quality controls, and global coverage into a single solution. Drawing on a vast network of official company registers, government publications, and other sources with strong credibility and reputation, Moody’s supports obliged entities by providing information that is independent and verifiable.
Moody’s applies systematic validation, cross-checking, and ongoing refresh cycles to deliver powerful data in a timely way, while clearly documenting source provenance and update frequency. As a result, Moody’s supports obliged entities with a robust foundation to identify and verify customers, understand ownership and control, and manage compliance activity related to AML due diligence.
Moody’s offers a full suite of data, workflows, and integrations to support customers with their AML/CFT compliance processes.
It is important to know who you are doing business with. With Moody’s solutions, customers can create greater transparency around beneficial ownership, control, and shareholder structures, to make decisions with greater confidence.
Moody's offers access to extensive, data on hundreds of millions of companies across the world. By integrating our solutions and datasets, customers can uncover robust beneficial ownership information — even across multiple ownership layers, international borders, and complex business networks.
Moody’s is a leading, global provider of ownership data, in terms of breadth, depth, and historical records. Ownership data is a key differentiator for our data estate, and our dedicated teams invest in obtaining, curating, and surfacing this important data for customers on an ongoing basis.
Moody’s remains committed to delivering timely, extensive, curated and integrated ownership data for a wide range of use cases across risk typologies and throughout control frameworks.
Since November 2022, when the BO registers public access provision was invalidated by the CJEU, Moody’s ownership links have grown from 20.8 million to 23.2 million in Eastern Europe and from 28.7 million to 32.0 million in Western Europe, thus growing our capabilities around delivering cross-border ownership insights.
Derived from multiple sources such as commercial registry and financial report filings, reputable news, Mergers & Acquisition (M&A) activity, fund movements, and other publicly or commercially available data, Moody’s ownership data provides shareholding links, control rights, and influence indicators across multiple jurisdictions to help determine the ultimate individual owner or controlling party, at percentage-thresholds determined by our customers’ preferences (e.g., 10%-50%).
The ultimate owners are computed based on proprietary algorithms and calculation methods, which include:
The AMLD6 from 2024 unified EU registry access rules, and in addition to competent authorities and obliged entities, it established several other categories of entities who have a legitimate interest in accessing the data held in these registries.
Access based on legitimate interest now encompasses providers of AML/CFT products (including Moody’s) to the strict extent that products developed based on this information are only provided to competent authorities or obliged entities. Member states had two years to set up the required procedures and structures to enable this, and Moody’s is licensed as an authorized service provider in several EU member states and is actively pursuing access to registries of beneficial owners based on this provision.
While AMLD6 requires registers of beneficial owners to make beneficial ownership data accessible in structured, machine-readable format and through providers of AML/CFT products, such as Moody’s, by mid-2026, registers of beneficial owners across the EU member states are at varying stages of technical development and the required transposition frameworks. Our teams are closely monitoring these developments and are adapting to make sure we are at the forefront of helping to address customer needs.
The following registries are currently still available through Moody's curated data offering with ongoing updates, normalized, standardized, and embedded with the rest of the data domains on an entity level. However, the landscape is dynamic, and access rules can change without notice or at short notice.
Below is an overview of registries of beneficial owners that Moody’s makes available through live registry connections to customers who are obliged entities. Moody’s provides this data as a passthrough service, embedded into Moody’s integrated data estate. The data is delivered ‘as is’ and is not stored in Moody’s systems but provided on a demand basis directly to obliged entities.
Publicly available and accessible through Moody’s live data solutions, regardless of obliged entity status
Available through Moody’s for obliged entities
Available through Moody’s for obliged entities through custom-builds
Known technical limitations for structured beneficial ownership data sourcing
For jurisdictions not categorized in the lists above, please reach out directly to the Moody’s team. We are happy to talk further about how we can support you to meet your completeness, effectiveness, and efficiency goals.
To discuss access to beneficial ownership data via Moody’s, or any other area of your AML/CFT program, please get in touch with the team. We would love to hear from you.
*Disclaimer: This content is for informational purposes only and does not constitute legal, financial, compliance or other professional advice. Please consult with a qualified professional for specific legal, financial, compliance, or other professional advice. For more terms and conditions pertaining to Moody’s products and services, refer to the disclaimer on Moody’s website.