Three tiers of debtor analysis exist because the sources that establish control are not uniform. A shareholder list in one jurisdiction is a filed document; in another it is a confidential internal record. What each tier covers, what it cannot reach, and where the chain stops — these are fixed before payment.
Control is the central question. Who holds the shares, who directs the company, and what enforcement rights attach to that position — these are the facts each tier is designed to establish from official registers and filed documents. The angle does not change across jurisdictions; the depth of what the sources allow does.
Scope of the analysisEach tier covers a defined set of sources: registry filings, insolvency records, and — where access conditions permit — beneficial ownership data. Source: VLO Law Firm analytical framework · verified 2026-09-15 Price tiersThree fixed tiers: Signal, Standard, Extended. Price is stated before the order is placed. No tier is priced on outcome. Access conditionsSome registers require a national identifier, a declaration of legitimate interest, or a registered local agent. These conditions are identified per jurisdiction before the order is accepted. What no tier coversNo tier produces a legal qualification of the facts established. The ceiling of what the sources allow is stated before payment.What each tier establishes
The three tiers are not versions of the same report at different price points. They address different layers of the control question.
Signal establishes the first layer: registered name, registered address, legal form, current status, and the identity of directors as filed. Where the register returns a shareholder list as a public document, that list is included. Signal does not pursue the chain beyond what the primary register returns in a single extraction.
Standard adds the second layer: filed financial statements where available, cross-reference against the insolvency register, and a check of the beneficial ownership register where public access exists. Standard identifies the point at which the chain stops and states the reason — whether that is a closed register, a missing filing, or a jurisdiction that does not require disclosure at that level.
Extended addresses the third layer: multi-jurisdiction chains, intermediate holding structures, and the reconciliation of data across registers that may disagree. Where a shareholder list names a corporate entity rather than a natural person, Extended traces that entity through its own jurisdiction's register to the next identifiable level. Extended states explicitly where the chain cannot be continued and why.
| Tier | Layer addressed | Core sources | Not included |
|---|---|---|---|
| Signal | Registration and directors | Primary company register | Insolvency check, UBO register, financial statements |
| Standard | Ownership and insolvency | Primary register + insolvency register + UBO register (where accessible) | Multi-jurisdiction chain, intermediate holding analysis |
| Extended | Control chain and structure | All Standard sources + registers of intermediate entities | Legal qualification, enforcement advice, court records |
Control: what the sources can and cannot establish
The control question has a ceiling in every jurisdiction. That ceiling is a function of what the register requires to be filed, what it makes publicly accessible, and what access conditions apply to a foreign applicant.
In jurisdictions where the shareholder list is a filed document — updated on each change of ownership — Signal returns current ownership data directly. In jurisdictions where the shareholder list is an internal document not required to be filed, Signal returns the register's output and states that ownership data is not available from this source.
The beneficial ownership register adds a layer in jurisdictions where it exists and where public access has not been restricted. Following the CJEU judgment in joined cases C-37/20 and C-601/20, public access to UBO registers across EU member states is not uniform. Where access requires a demonstration of legitimate interest, the access condition is identified and the request is structured accordingly. Where access is closed to foreign applicants without a local representative, that constraint is stated before the order is accepted.
Financial statements, where filed and publicly accessible, establish whether the reported ownership structure is consistent with the economic reality of the entity. Discrepancies between the shareholder register and the financial statements are reported as a finding, not resolved by inference.
Where the sources disagree
Disagreement between sources is a result, not a gap. When the company register names one director and the insolvency register names a different administrator, both facts are reported with their respective sources and dates. When the beneficial ownership register names a natural person and the shareholder list names a corporate entity, the discrepancy is identified and the Extended tier traces the corporate entity through its own register.
No tier resolves disagreement by choosing one source over another. The report states what each source shows, the date of extraction, and the nature of the discrepancy.
The limit of what the sources allow
The ceiling of what the sources allow is stated before payment. This is not a disclaimer appended after the fact; it is the first output of the scoping process.
Specific limits that apply across the tier structure:
- Registers that require a national identifier to return results cannot be queried without one. Where a national identifier is not available from public sources, the register is listed as inaccessible for this object, and the reason is stated.
- Jurisdictions that do not require beneficial ownership disclosure produce no beneficial ownership data. The absence of a filing is not evidence of absence of a beneficial owner.
- Insolvency registers in several jurisdictions remove personal data after defined retention periods. A negative result does not confirm that no proceeding was ever filed; it confirms that no current record exists within the retention window.
- Delaware LLCs do not disclose members in the public register. The register returns the registered agent and the formation date. Ownership data for a Delaware LLC is not available from the primary register at any tier.
- VIES confirms VAT registration status. It does not return the company name or address for all member states. A negative VIES result does not establish that the entity does not exist.
The Extended tier does not overcome these limits. It establishes the chain to the furthest point the sources permit and names the point at which the chain stops.
What is included at each tier: a structured comparison
| Element | Signal | Standard | Extended |
|---|---|---|---|
| Registered name and address | ✓ | ✓ | ✓ |
| Legal form and current status | ✓ | ✓ | ✓ |
| Directors as filed | ✓ | ✓ | ✓ |
| Shareholder list (where filed publicly) | ✓ | ✓ | ✓ |
| Insolvency register check | — | ✓ | ✓ |
| UBO register (where accessible) | — | ✓ | ✓ |
| Filed financial statements | — | ✓ | ✓ |
| Intermediate holding entity check | — | — | ✓ |
| Multi-jurisdiction chain | — | — | ✓ |
| Source disagreement reconciliation | — | — | ✓ |
| Legal qualification of findings | — | — | — |
| Enforcement advice | — | — | — |
How the scope is confirmed before the order
Each order begins with a jurisdiction and object identification step. The sources available for that jurisdiction are identified, the access conditions are checked, and the ceiling of what the sources allow is stated. If the object falls below the threshold of what a given tier can establish — because the jurisdiction does not require the relevant filings, or because access conditions cannot be met — that is communicated before the order proceeds.
This step is not billable. It is the basis on which the scope of the report is agreed.
FAQ
Does the Signal tier establish who controls the company? Signal establishes who is registered as a director and, where the shareholder list is a public filed document, who holds shares and in what proportion. Where ownership data is not available from the primary register, Signal states that and identifies the reason. Signal does not trace the chain beyond the primary register.
What happens when the shareholder is a corporate entity, not a natural person? At Signal and Standard, the corporate shareholder is identified by name, jurisdiction, and registration number. The chain is not traced further at those tiers. At Extended, the corporate shareholder's own register is queried and the chain is traced to the next identifiable level. Where the chain passes through a jurisdiction that does not disclose ownership, that point is named and the reason is stated.
Is the insolvency check included in Signal? No. The insolvency register check is included from Standard upward. Signal covers the primary company register only.
Can the Extended tier establish the ultimate beneficial owner in every case? No. The Extended tier traces the chain to the furthest point the sources permit. Where a jurisdiction does not require beneficial ownership disclosure, or where the UBO register is closed to the access conditions available, the chain stops at that point. The stopping point and the reason are stated in the report.
What does "source disagreement" mean in practice? When two official sources return different data about the same entity — for example, the company register shows one director and the insolvency register shows a different administrator — both facts are reported with their respective sources and extraction dates. The Extended tier identifies the discrepancy and states what each source shows. No tier resolves the discrepancy by inference or by preferring one source over another.
Is the price fixed before the order? Yes. Each tier carries a fixed price. The scope is confirmed before the order is accepted. No tier is priced on outcome or on the volume of data returned.
Sources:
VLO Law Firm analytical framework — internal scope documentation — verified 2026-09-15
CJEU joined cases C-37/20 and C-601/20 — curia.europa.eu — reference date 2026-09-15
European Business Register network — ebr.org — extracted 2026-09-20
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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
