Control over a company is not always visible at the first registry layer. The shareholder of record may hold shares on behalf of another party; the director named in the filing may act under a power of attorney held elsewhere. Establishing who actually controls the counterparty — and what rights attach to that control — requires working through several source layers in sequence.
The time that process takes is not fixed. It depends on which jurisdictions are in the chain, which registers are open to foreign applicants, and whether the sources agree with each other. This page sets out the variables that govern turnaround, the ceiling of what the sources allow, and where the chain typically stops.
What the process establishesThe registered ownership layer, the directorship layer, and — where the register permits — the beneficial ownership layer. Each layer has its own source, access condition, and response time. Turnaround rangeSingle-jurisdiction registry extraction: typically one to five business days. Multi-jurisdiction chains: five to fifteen business days, depending on access conditions in each jurisdiction. Verified as the operative range across the 35 jurisdictions covered by this practice as of 2026-09-15. What governs the ceilingThe slowest jurisdiction in the chain sets the delivery date. A register that requires a declared legitimate interest, a notarised request, or a national identifier adds processing time that cannot be compressed. What the sources do not showNominee arrangements, trust deeds, and side agreements are not filed in any public register. Their existence can sometimes be inferred from structural patterns; it cannot be confirmed from registry data alone.Source: VLO Law Firm practice data across 35 jurisdictions · verified 2026-09-15
What drives turnaround on a counterparty check
The time required to establish control and shareholder rights breaks into four distinct phases. Each phase has its own ceiling.
Phase 1 — Jurisdiction identification. Before any register is queried, the applicable jurisdiction must be confirmed. A company incorporated in one state may be registered as a foreign entity in another; its operating subsidiary may sit in a third. Identifying the correct register for each layer takes one business day in straightforward structures and up to three in layered ones.
Phase 2 — Registry access. Some registers return data the same day. Others require registration, a national tax identifier, or a declaration of legitimate interest filed in the local language. Where electronic access is unavailable, a physical request must be submitted through a local correspondent. Access conditions — not the size of the company — are the primary driver of delay.
Phase 3 — Document processing. Registry documents arrive in the language of the jurisdiction. Translation, cross-referencing against other layers, and reconciliation of discrepancies between sources add time proportional to the number of jurisdictions in the chain.
Phase 4 — Gap identification. The final step is stating explicitly where the chain stops and why. A chain that terminates at a nominee shareholder in a jurisdiction that does not disclose beneficial ownership is a result, not a failure. That result is delivered with the same precision as a complete chain.
Access conditions by register type
The table below maps the main register categories to their typical access conditions and the effect on turnaround. Specific fees are not stated here because they are set by each registrar and published in its own tariff schedule; the mechanism is described instead.
| Register type | Access condition | Effect on turnaround |
|---|---|---|
| Open commercial register (no login required) | None | Same day to one business day |
| Register requiring account registration | Account creation, sometimes national ID | One to three business days |
| Register requiring declared legitimate interest | Written declaration, sometimes notarised | Three to seven business days |
| Register with local-correspondent-only access | Physical submission through in-country agent | Five to fifteen business days |
| Beneficial ownership register (post-CJEU C-37/20) | Varies by member state; most EU registers now restrict public access | Unpredictable; outcome not guaranteed |
The slowest register in the chain determines the delivery date for the full report. Where one jurisdiction requires a physical submission, the remaining jurisdictions are processed in parallel so that no additional delay accumulates.
Control and shareholder rights: what the sources cover
Establishing control means establishing two things: who holds the shares, and who can exercise the rights attached to those shares. These are not always the same person.
Registered shareholders appear in the commercial register or the shareholders' list filed with it. In jurisdictions where that list is publicly accessible, the registered holder, the share percentage, and the date of the last filing are extractable. The filing date matters: a shareholders' list that has not been updated since incorporation may not reflect subsequent transfers.
Directors and authorised signatories appear in the commercial register. The scope of their authority — whether they act jointly or severally, whether their mandate is limited — is stated in the articles or in a separate power of attorney. The articles are a filed document in most jurisdictions; the power of attorney may not be.
Beneficial owners appear in a UBO or PSC register where one exists and where access is permitted. Following the Court of Justice of the European Union ruling in Case C-37/20, public access to beneficial ownership registers in EU member states has been restricted by default. Access conditions vary by member state and are confirmed before each instruction is accepted.
Shareholder agreements are private contracts. They are not filed in any public register. Their existence may be disclosed in filed financial statements or in prospectus documents where the company has issued public securities; otherwise they are not visible from registry data.
Where the sources disagree
Where the sources disagree, the disagreement is reported as a result.
A shareholders' list showing one ownership structure and a filed annual return showing a different one is not a data error to be resolved before delivery. It is a fact about the counterparty: the two sources are inconsistent, and the date of each filing is stated so that the sequence can be assessed.
Common patterns of disagreement across the 35 jurisdictions covered by this practice include:
- A shareholders' list filed at incorporation that has not been updated to reflect subsequent transfers
- A director named in the commercial register who no longer holds the position according to the company's own filings
- A beneficial owner declared in a UBO register whose identity differs from the ultimate shareholder visible in the corporate chain
Each pattern is documented with the source, the filing date, and the nature of the discrepancy. No interpretation of the legal significance of the discrepancy is provided; that analysis sits with legal counsel instructed separately.
The limit of what the sources allow
The ceiling of what the sources allow is stated before payment. This section sets out that ceiling explicitly.
What the sources establish with precision: the registered ownership layer as of the last filed update; the directorship layer as of the last filed update; the beneficial ownership layer where the applicable register is open and the access condition is met.
What the sources establish with qualification: the date of the last update to each layer. A register that is updated on filing, not on a periodic schedule, may lag the actual position by months or years. The filing date is always stated; the gap between the filing date and the date of extraction is always noted.
What the sources cannot establish: nominee arrangements not disclosed in any filing; trust structures not registered in a public trust register; side agreements between shareholders; the actual exercise of control where it diverges from the formal ownership structure.
Where the chain stops: in jurisdictions that do not require beneficial ownership disclosure, the chain terminates at the last registered layer. The jurisdiction, the applicable rule, and the layer at which the chain stops are all named in the report. A chain that stops at a known point is a precise result.
The 35-jurisdiction scope: not every jurisdiction in the scope has an open, accessible register at every layer. Before an instruction is accepted, the access conditions for the specific jurisdictions in the counterparty's structure are confirmed. Where a register is inaccessible to a foreign applicant without a local correspondent, that condition is disclosed upfront.
Frequently asked questions
How is the turnaround calculated? The clock starts when the instruction is confirmed and the jurisdictions in the counterparty's structure are identified. The delivery date is set by the slowest register in the chain. Where a register requires a physical submission through a local correspondent, that submission is made on the first business day after instruction confirmation.
What happens if a register is temporarily unavailable? Temporary unavailability — scheduled maintenance, system outages — is reported immediately. The instruction is held open; no substitution of a secondary source is made without explicit agreement. The delivery date is adjusted to reflect the actual availability of the primary source.
Does the report cover subsidiaries? The scope of the instruction determines the scope of the report. A counterparty check covers the entity named in the instruction. Subsidiaries, parent companies, and affiliated entities are covered only if they are named in the instruction or if their inclusion is agreed before the instruction is confirmed.
What if the counterparty is incorporated in a jurisdiction not in the 35-jurisdiction scope? Access conditions for jurisdictions outside the standard scope are assessed on a case-by-case basis before the instruction is accepted. Where access is not feasible, that is stated before any fee is agreed.
Is the report updated after delivery? The report reflects the state of the sources at the date of extraction. It is not a monitoring service. A new instruction is required to reflect changes after the delivery date.
What language are the source documents in? Source documents are delivered in the language of the jurisdiction. A working summary in English is included for each document. Certified translation is available as a separate instruction.
Sources
VLO Law Firm practice data across 35 jurisdictions — verified 2026-09-15
For register-specific access conditions and official tariff schedules, consult the registrar of the applicable jurisdiction directly. Registry source names and official URLs are provided in each delivered report alongside the extracted documents.
Request this report
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: Elena Moretti — Partner, Continental Europe, VLO Law Firm
