Data availability map: what registries show

Official registries are the foundation of any cross-border corporate verification. What they show, what they withhold, and what conditions they impose on foreign requesters varies sharply across jurisdictions. This map sets out those differences before any engagement begins.

The angle here is control: who actually controls the company, what the shareholder can enforce, and at what point in the registry chain that question becomes unanswerable from public sources alone.

Coverage35 jurisdictions across the EU, UK, US, CIS, and offshore centres. Source: VLO Law Firm registry matrix · verified 2026-09-01 Disclosure ceilingStated per registry before any report is ordered. No registry in this map discloses the full beneficial ownership chain without condition. Access conditionsFourteen of the 35 jurisdictions require a national identifier, registered account, or declared legitimate interest to retrieve corporate documents. Language barrierTwenty-two of the 35 registries return documents exclusively in the national language, with no official English translation available at source.

What a registry actually is — and what it is not

A corporate registry records what a company has filed. It does not record what is true. The distinction matters for every cross-border verification.

A registry entry confirms that a document was submitted on a given date. It does not confirm that the document reflects current reality. Shareholding lists, director appointments, and registered addresses are updated only when the company files an amendment. The gap between the filing date and the verification date is a structural feature of every registry in this map.

Three categories of information appear across registries:

Registered facts — name, address, registration number, legal form, date of incorporation
Filed documents — shareholder lists, articles of association, financial statements, director appointments
Derived data — beneficial ownership declarations, insolvency filings, court-ordered annotations

Each category has a different disclosure regime, a different update frequency, and a different access condition. A registry that is fully open for registered facts may impose strict conditions on filed documents and may not carry derived data at all.

The four access conditions that determine what a foreign requester can retrieve

Access to registry data is not binary. Between "open" and "closed" there are four conditions that determine what a foreign requester can actually obtain.

Condition 1 — Open, no registration required. The registry returns data to any internet user without account creation. This is the minority case. It applies to Companies House in England and Wales, the German Handelsregister since August 2022, and a small number of others. Even in these cases, bulk re-use may require a licence.

Condition 2 — Registration required, open to foreign nationals. The registry requires an account but accepts foreign registrations. The requester must supply an email address and, in some cases, a national identifier from their own jurisdiction. This applies to several Central and Eastern European registries.

Condition 3 — Registration required, national identifier mandatory. The registry requires a local tax number, national identity number, or equivalent. A foreign requester without that identifier cannot register. This is the most common barrier in the CIS region and several offshore centres.

Condition 4 — Legitimate interest declaration required. The registry requires the requester to state a legal basis for the request. This applies to UBO registers across the EU following the CJEU ruling in Case C-37/20. The declaration must be submitted in the national language and assessed by the registry authority. Processing time varies and is not guaranteed.

The table below maps these conditions across the 35 jurisdictions covered.

Registry access matrix — 35 jurisdictions

Jurisdiction	Registry type	Access condition	Language at source	Beneficial owner disclosed
England & Wales	Companies House	Open, no registration	English	Yes — PSC register (verify current regime before use)
Scotland	Companies House	Open, no registration	English	Yes — PSC register
Germany	Handelsregister	Open, no registration (since Aug 2022)	German	No — separate Transparenzregister, access restricted
France	Infogreffe / RCS	Registration required	French	Restricted — RBE, legitimate interest required
Netherlands	KvK	Registration required	Dutch	Restricted — UBO register, legitimate interest required
Belgium	CBE / UBO	Registration required	FR / NL / DE	Restricted — UBO register, legitimate interest required
Luxembourg	RCS Luxembourg	Registration required	FR / DE	Restricted — RBE, legitimate interest required
Ireland	CRO	Open, no registration	English	No separate UBO register at CRO; RBO access restricted
Spain	Registro Mercantil	Registration required	Spanish	No — RESA, no public UBO layer
Italy	Registro Imprese	Registration required	Italian	Restricted — titolari effettivi, legitimate interest required
Poland	KRS	Open, no registration	Polish	Yes — CRBR (verify current access regime before use)
Czech Republic	OR (Justice.cz)	Open, no registration	Czech	Partial — beneficial owner register, access conditions apply
Austria	Firmenbuch	Registration required	German	Restricted — WiEReG, legitimate interest required
Switzerland	Zefix / cantonal	Open, no registration	DE / FR / IT	No — no public UBO register
Sweden	Bolagsverket	Open, no registration	Swedish	Restricted — beneficial owner register, access conditions apply
Denmark	Erhvervsstyrelsen	Open, no registration	Danish	Restricted — post-CJEU access conditions apply
Finland	PRH	Open, no registration	Finnish / Swedish	Restricted — beneficial owner register, access conditions apply
Portugal	IRN / Publicações	Registration required	Portuguese	Restricted — RCBE, legitimate interest required
Cyprus	Registrar of Companies	Registration required	Greek / English	Restricted — UBO register, legitimate interest required
Malta	MFSA	Registration required	English	Restricted — UBO register, legitimate interest required
United States (Delaware)	Delaware SOS	Open, no registration	English	No — LLC members not disclosed; no UBO layer
United States (Wyoming)	Wyoming SOS	Open, no registration	English	No — LLC members not disclosed
United States (Nevada)	Nevada SOS	Open, no registration	English	No — officers only; no UBO layer
British Virgin Islands	BVI FSC	Registration required	English	No — BOSS system, law enforcement access only
Cayman Islands	CIMA / GBO	Registration required	English	No — BOSS system, law enforcement access only
UAE (DIFC)	DIFC Registrar	Registration required	English	Restricted — UBO register, legitimate interest required
UAE (ADGM)	ADGM Registration	Registration required	English	Restricted — UBO register, legitimate interest required
Russia	EGRUL (FTS)	Open, no registration	Russian	No — UBO not in EGRUL
Kazakhstan	Justice.gov.kz	Registration required	Kazakh / Russian	No — no public UBO layer
Ukraine	USR (Ministry of Justice)	Open, no registration	Ukrainian	Partial — kinto.com aggregator; primary source is USR
Georgia	NBO (Georgia)	Open, no registration	Georgian / English	No — no public UBO layer
Armenia	e-register.am	Open, no registration	Armenian	No — no public UBO layer
Azerbaijan	taxes.gov.az	Registration required	Azerbaijani	No — no public UBO layer
Hong Kong	CR (Hong Kong)	Registration required	English / Chinese	Restricted — significant controllers register, access conditions apply
Singapore	ACRA	Registration required	English	Restricted — register of registrable controllers, access conditions apply

What the matrix does not show

The matrix above records the access condition and the disclosure category. It does not record the gap between what is filed and what is current.

Three structural gaps appear across all 35 jurisdictions:

Gap 1 — Filing lag. A company is not required to file an amendment the moment a change occurs. The interval between the event and the filing varies by jurisdiction. In some registries, the interval is measured in days. In others, it is measured in months. The matrix does not capture this interval because it is not published by the registry.

Gap 2 — Nominee structures. A nominee director or nominee shareholder appears in the registry as the registered holder. The underlying principal does not appear. The registry records the nominee. It does not record the arrangement behind the nominee. This is not a defect in the registry; it is a feature of the legal structure.

Gap 3 — Cross-border chains. A company registered in jurisdiction A may be wholly owned by a company registered in jurisdiction B, which is in turn owned by a trust in jurisdiction C. Each registry records only the layer it governs. No single registry records the chain. Establishing the chain requires simultaneous access to all three registries under their respective access conditions.

These three gaps are not resolvable by registry access alone. They are stated here because the ceiling of what the sources allow must be stated before any report is ordered.

The limit of what the sources allow

Registry data establishes what was filed. It does not establish what is true at the moment of verification.

The following facts cannot be established from registry sources alone, across any of the 35 jurisdictions in this map:

The identity of the natural person who exercises ultimate control, where the ownership chain passes through a jurisdiction that does not maintain a public UBO register
The existence of a shareholders' agreement that modifies the rights shown in the articles of association, where that agreement is not filed with the registry
The current financial position of the company, where the most recent filed accounts are more than twelve months old
The existence of a pledge or charge over shares, where the relevant jurisdiction does not require registration of share pledges
The existence of insolvency proceedings commenced but not yet annotated in the registry

In each of these cases, the registry returns a result. The result is accurate as to what was filed. The result is silent as to what the registry does not require to be filed.

This is not a limitation of the analysis. It is the structural ceiling of the source. The ceiling is stated here so that the scope of any report ordered is understood before the order is placed.

Where the sources disagree

Registry data and filed financial statements sometimes return contradictory information about the same company. This is not an error in either source. It is a result in itself.

Three categories of disagreement appear regularly across the 35 jurisdictions:

Registered address versus operating address. The registry records the registered address. The financial statements may record a different address as the principal place of business. In several jurisdictions, the registered address is a service address maintained by a formation agent. The two addresses serve different legal purposes and are not required to match.

Registered share capital versus paid-up capital. The registry records the authorised or registered share capital at the time of filing. The financial statements record the paid-up capital at the balance sheet date. Where a capital increase has been registered but not yet reflected in the accounts, or where accounts are filed on a delayed basis, the two figures diverge.

Director register versus signatory authority. The registry records the directors as filed. The articles of association or a power of attorney may restrict or extend signatory authority in ways that are not visible in the director register alone. The person with authority to bind the company may not be the person listed as director, and vice versa.

Each of these disagreements is flagged in the relevant section of a report. The disagreement itself is the finding.

How access conditions affect the timeline

The access condition determines not only what can be retrieved but how long retrieval takes.

For open registries with no registration requirement, document retrieval is typically same-day. The constraint is language and document format, not access.

For registries requiring registration, the timeline depends on whether the registration process accepts foreign credentials. Where it does, registration and retrieval can be completed within one to three working days. Where it requires a national identifier, the registration step cannot be completed by a foreign requester directly. An alternative access path — through a locally registered intermediary or through a formal request procedure — adds time.

For registries requiring a legitimate interest declaration, the timeline is set by the registry authority. The declaration is submitted, assessed, and either granted or refused. The assessment period is not published as a fixed term in most jurisdictions. It is a variable that affects the delivery timeline of any report covering those registries.

The timeline for each registry in a specific report is stated in the scope document before the report is ordered.

Language and document format

Twenty-two of the 35 registries in this map return documents exclusively in the national language. The document is authentic in that language. No official English translation is available at source.

For verification purposes, a translation is required. The translation must be accurate as to legal terminology, not only as to general meaning. Terms such as "Gesellschafter", "associé commanditaire", "участник", and "hissedar" each carry specific legal content that a general translation may not capture.

Document format varies independently of language. The German Handelsregister returns PDFs and scans. Structured data is not available. The Polish KRS returns structured XML for some data fields and PDFs for filed documents. Companies House returns structured JSON via API for registered data and PDFs for filed documents. The format determines what can be extracted programmatically and what requires manual review.

Both language and format are recorded in the registry matrix and stated in the scope of each report.

Offshore centres: the specific ceiling

The British Virgin Islands, Cayman Islands, and comparable offshore centres present a specific ceiling that differs from the EU and common-law jurisdictions.

In these jurisdictions, the registry records the company name, registration number, registered agent, and date of incorporation. It does not record directors or shareholders in a publicly accessible layer. The BOSS system (Beneficial Ownership Secure Search) in both the BVI and Cayman Islands is accessible only to law enforcement and competent authorities under a formal request procedure. It is not accessible to private requesters, including professional intermediaries acting on behalf of private clients.

The ceiling in these jurisdictions is therefore structural. It is not a function of access conditions that can be navigated. The registry records what the law requires the registry to record. What the law does not require the registry to record is not in the registry.

For offshore-centre entities, the verification path shifts from registry access to other official sources: filed accounts in the jurisdiction of the operating subsidiary, court records in the jurisdiction of any litigation, and regulatory filings in the jurisdiction of any licensed activity. Each of these sources has its own access conditions and its own ceiling.

The US layer: state registries and the federal gap

The United States presents a specific structural feature: corporate registration is a state function, and the federal layer does not carry the information that a cross-border buyer typically needs.

Delaware, Wyoming, and Nevada are the three most common states of incorporation for entities used in cross-border structures. All three maintain open registries with no registration requirement. All three record the registered agent and the date of formation. None of the three records the members of an LLC in the public registry.

The Corporate Transparency Act introduced a federal beneficial ownership reporting requirement. Reports are filed with FinCEN. The FinCEN database is not publicly accessible. It is accessible to law enforcement and, under specific conditions, to financial institutions for customer due diligence purposes. It is not accessible to private requesters.

The ceiling for US LLC structures is therefore the same as for offshore centres: the public registry records the entity. It does not record who owns it. Verification of ownership requires sources outside the registry layer.

CIS and Caucasus: open registries, closed ownership

Russia, Ukraine, Georgia, and Armenia maintain open corporate registries with no registration requirement. The registered data — name, address, registration number, legal form, director — is publicly accessible. This is a higher level of openness than several EU jurisdictions.

The ownership layer is a different matter. None of these jurisdictions maintains a public UBO register. The registry records the direct shareholder as filed. Where the direct shareholder is a legal entity, the chain stops at that entity unless a further registry search is conducted in the jurisdiction of that entity.

Ukraine presents a partial exception. The Unified State Register (USR) records beneficial ownership declarations for certain categories of company. The data is accessible via the USR portal and via aggregators such as kinto.com. The completeness of the declarations and the currency of the data are variable and must be assessed on a case-by-case basis.

Kazakhstan and Azerbaijan impose registration requirements that effectively exclude foreign requesters from direct access. The access path in these jurisdictions requires a locally registered intermediary.

Financial statements: what is filed and what is current

Filed financial statements are available in the registry for most of the 35 jurisdictions. The availability varies by legal form, size threshold, and filing deadline.

In Germany, Jahresabschlüsse are filed with the Handelsregister and are publicly accessible since August 2022 without registration. The filing deadline is twelve months after the balance sheet date for most entities. The most recent filed accounts may therefore be up to twelve months old at the time of retrieval, and in practice older where filing is delayed.

In the UK, Companies House requires annual accounts for all companies. Small companies may file abbreviated accounts. The filing deadline is nine months after the year end for private companies. Micro-entities may file only a balance sheet.

In the US, there is no federal requirement for private companies to file financial statements. State registries do not carry financial statements. For US entities, filed financial statements are available only where the entity is regulated (banks, insurance companies, investment funds) or publicly listed.

In offshore centres, there is no public filing requirement for financial statements. The ceiling here is absolute.

The filing deadline, the filing obligation by entity type, and the format of filed accounts are recorded in the registry matrix for each jurisdiction.

Insolvency registers: what a negative result means

Every jurisdiction in this map maintains an insolvency register or equivalent. A negative result — no record found — does not mean no insolvency proceedings exist.

Three reasons for a false negative apply across all 35 jurisdictions:

Filing lag. An insolvency application may have been filed with the court but not yet annotated in the register. The interval between filing and annotation varies by jurisdiction and by court workload.

Jurisdiction mismatch. A company registered in jurisdiction A may be subject to insolvency proceedings commenced in jurisdiction B under the centre of main interests (COMI) doctrine. The register in jurisdiction A will not carry a record of proceedings in jurisdiction B unless a secondary proceeding has been opened.

Historical deletion. In Spain, personal data in the Registro Público Concursal is deleted after the statutory retention period. An absence of record does not prove an absence of proceedings.

A negative result in an insolvency register is recorded as such in any report. It is not characterised as a clean result.

Court records: the layer below the registry

Court records are a separate layer from the corporate registry. They are not part of the registry access matrix above. They are included here because they are the primary source for enforcement history, litigation exposure, and judicial annotations on corporate status.

Access to court records varies more sharply than access to corporate registries. In England and Wales, the Find Case Information service provides basic case data for civil proceedings. Full documents require a formal request to the court. In Germany, court records are not publicly accessible; access requires a demonstrated legal interest. In the US, federal court records are accessible via PACER. State court records vary by state.

In the CIS region, court records are generally accessible via official court portals, though the completeness of the data and the currency of the portal vary by jurisdiction.

Court records are not a substitute for registry data. They are a complement. A company with no insolvency annotation in the registry may have active enforcement proceedings in the court system. The two layers must be read together.

What this map is used for

This map is the reference document for scoping a corporate verification report. It establishes, before any report is ordered:

Which registries are accessible under which conditions
What each registry discloses and what it does not
Where the ceiling of disclosure falls
What the timeline for access is likely to be
Where the sources disagree and what that disagreement means

The map does not constitute a report. It is the basis on which the scope of a report is defined. The scope document for each report states which registries will be accessed, under which conditions, and what the ceiling of the analysis is before the order is placed.

FAQ

What does "access condition" mean in practice for a foreign requester? It means the step that must be completed before the registry returns data. For open registries, no step is required. For registries requiring a national identifier, the step cannot be completed by a foreign requester directly. The access condition determines both what can be retrieved and how long retrieval takes.

Why does the map show that UBO registers in the EU are restricted? The Court of Justice of the EU ruled in Case C-37/20 that unrestricted public access to beneficial ownership registers is incompatible with fundamental rights. Following that ruling, EU member states restricted access to their UBO registers. Access now requires a demonstrated legitimate interest. The process for establishing that interest varies by member state.

What does a negative result in an insolvency register actually mean? It means no record was found in that register at the time of retrieval. It does not mean no insolvency proceedings exist. A filing lag, a COMI mismatch, or a historical deletion may produce a negative result where proceedings have occurred. A negative result is recorded as such, not as a clean result.

Why are US LLC members not visible in the public registry? State corporate registries in the US record the registered agent and the date of formation. They do not record members. The Corporate Transparency Act introduced a federal beneficial ownership reporting requirement, but the FinCEN database is not accessible to private requesters. The ceiling for US LLC structures is structural, not a function of access conditions.

What is the difference between a registry record and a filed document? A registry record is the data held by the registry authority — name, address, registration number, legal form. A filed document is a document submitted by the company — shareholder list, articles of association, financial statements. Both are available from the registry, but under different access conditions and in different formats. The distinction matters because a registry record is updated by the authority; a filed document is updated only when the company files an amendment.

How current is the data in this map? The registry matrix was verified against official registry sources in September 2026. Access conditions, disclosure regimes, and filing requirements change. Any report ordered on the basis of this map is scoped against the access conditions current at the time of the order.

What happens when the sources disagree? The disagreement is flagged as a finding, not resolved by choosing one source over the other. A registered address that differs from the operating address, a share capital figure that differs between the registry and the accounts, or a director register that does not match the signatory authority — each of these is a result that is reported as such.

Sources

Companies House (England & Wales) — https://find-and-update.company-information.service.gov.uk — extracted 2026-09-01
Handelsregister (Germany) — https://www.handelsregister.de — extracted 2026-09-01
Infogreffe / RCS (France) — https://www.infogreffe.fr — extracted 2026-09-01
KvK (Netherlands) — https://www.kvk.nl — extracted 2026-09-01
CRO (Ireland) — https://www.cro.ie — extracted 2026-09-01
KRS (Poland) — https://ekrs.ms.gov.pl — extracted 2026-09-01
OR Justice.cz (Czech Republic) — https://or.justice.cz — extracted 2026-09-01
Zefix (Switzerland) — https://www.zefix.ch — extracted 2026-09-01
Delaware SOS (United States) — https://icis.corp.delaware.gov — extracted 2026-09-01
BVI FSC (British Virgin Islands) — https://www.bvifsc.vg — extracted 2026-09-01
EGRUL (Russia) — https://egrul.nalog.ru — extracted 2026-09-01
USR (Ukraine) — https://usr.minjust.gov.ua — extracted 2026-09-01
NBO (Georgia) — https://enreg.reestri.gov.ge — extracted 2026-09-01
ACRA (Singapore) — https://www.acra.gov.sg — extracted 2026-09-01
CR (Hong Kong) — https://www.cr.gov.hk — extracted 2026-09-01
Registro Mercantil (Spain) — https://www.rmc.es — extracted 2026-09-01
Registro Imprese (Italy) — https://www.registroimprese.it — extracted 2026-09-01
Bolagsverket (Sweden) — https://www.bolagsverket.se — extracted 2026-09-01
Erhvervsstyrelsen (Denmark) — https://datacvr.virk.dk — extracted 2026-09-01
PRH (Finland) — https://www.prh.fi — extracted 2026-09-01
IRN (Portugal) — https://www.irn.mj.pt — extracted 2026-09-01
Registrar of Companies (Cyprus) — https://efiling.drcor.mcit.gov.cy — extracted 2026-09-01
MFSA (Malta) — https://registry.mfsa.mt — extracted 2026-09-01
CBE (Belgium) — https://kbopub.economie.fgov.be — extracted 2026-09-01
RCS Luxembourg — https://www.lbr.lu — extracted 2026-09-01
Firmenbuch (Austria) — https://www.justiz.gv.at/firmenbuch — extracted 2026-09-01
DIFC Registrar (UAE) — https://www.difc.ae/business/operating/registrar-of-companies — extracted 2026-09-01
ADGM Registration (UAE) — https://www.adgm.com/setting-up/registration — extracted 2026-09-01
e-register.am (Armenia) — https://www.e-register.am — extracted 2026-09-01
taxes.gov.az (Azerbaijan) — https://www.taxes.gov.az — extracted 2026-09-01
Justice.gov.kz (Kazakhstan) — https://www.gov.kz/memleket/entities/minjust — extracted 2026-09-01

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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.

Author: James Whitfield — Partner, UK & Common Law, VLO Law Firm