Beneficial ownership (UBO) thresholds by jurisdiction
Most jurisdictions set the beneficial ownership threshold at 25 percent of shares or votes, sometimes as “more than” and sometimes as “at least” 25 percent. Exceptions include India with more than 10 percent for companies and South Africa with 5 percent. In the US, CTA reporting has applied only to foreign companies since August 2026.
Last updated: 07.11.2026
Anyone administering structures across several countries must assess beneficial owners under different rules. This overview shows the ownership thresholds of the jurisdictions most relevant to family offices, fiduciaries and asset managers.
The threshold is only the first test. Almost everywhere, whoever controls a company by other means also counts, and trusts and foundations have their own roles.
| Jurisdiction | Threshold | Legal basis | Note | Explainer |
|---|---|---|---|---|
| Switzerland (banks, CDB 20) | 25 % or more of votes or capital; otherwise control by other means; fallback: managing person | CDB 20, Art. 4 AMLA | For domiciliary companies the beneficial owner of the assets counts (Form A) | Explainer |
| Switzerland (transparency register) | At least 25 % of capital or votes, alone or in concert, or control by other means | Art. 4 TJPG | Reporting to the register since 1 October 2026 | Explainer |
| EU (until July 2027) | Ownership of more than 25 % | 4th and 5th Anti-Money Laundering Directives, national transposition | Details per member state | |
| EU AMLR (from 10 Jul 2027) | 25 % or more of shares, voting rights or other ownership interest | Regulation (EU) 2024/1624 | The Commission may set lower thresholds down to 15 % for risk categories | Explainer |
| Germany | More than 25 % of capital or voting rights or comparable control | Section 3 GwG (DE) | Entry in the transparency register | |
| Austria | More than 25 % (25 % plus one share or an interest above 25 %) | WiEReG, FM-GwG | Reporting to the beneficial owners register | |
| United Kingdom | More than 25 % of shares or voting rights | Companies Act 2006 (PSC regime), Money Laundering Regulations 2017 | Register of persons with significant control | |
| United States (CTA) | At least 25 % of ownership interests or substantial control | Corporate Transparency Act, final rule of August 2026 | Reporting only for foreign reporting companies, excluding US persons; banks still collect under the CDD Rule | |
| India | More than 10 % for companies | Prevention of Money-laundering Rules (2023 amendment) | Lower than the international standard | |
| South Africa | 5 % or more | Companies Act (2023 amendments) | One of the lowest thresholds worldwide | |
| Singapore | More than 25 % | Companies Act, Register of Registrable Controllers | Register kept by the company, access for authorities | |
| Hong Kong | More than 25 % | Companies Ordinance, Significant Controllers Register | Register kept by the company | |
| United Arab Emirates | 25 % or more | Cabinet Resolution No. 109 of 2023 | Register with the competent registrar |
Notes
- Legal position as of 7 November 2026. Wordings such as “more than 25 %” and “25 % or more” differ exactly at a 25 % holding and must be observed.
- Indirect holdings through chains and persons acting in concert are aggregated in most jurisdictions.
- The overview does not replace legal assessment of individual cases.
Frequently asked questions
Which threshold applies to cross-border structures?
Each jurisdiction applies its own threshold, so a person can be a beneficial owner in one country and not in another.
Does the CTA still apply to Swiss companies?
Only if a Swiss company is registered to do business in the US and therefore counts as a foreign reporting company. US companies themselves have been exempt since the August 2026 final rule.
How does FLIORE handle this?
FLIORE assesses each person under the rules of their own jurisdiction and shows per mandate who is reportable and where enhanced due diligence is needed.
Sources
- Swiss Anti-Money Laundering Act (AMLA, SR 955.0)
- Agreement on the Swiss banks’ code of conduct with regard to the exercise of due diligence (CDB 20)
- Regulation (EU) 2024/1624 (AMLR) (EUR-Lex)
- FinCEN: Beneficial Ownership Information Reporting Requirement Revision, 91 Fed. Reg. 52508 (14 Aug 2026)