Every factual claim in a VLO report traces back to a named official source with a retrieval date. Control — who holds voting rights, who can bind the company, what a shareholder can enforce — is established from those sources, not inferred. The ceiling of what the sources allow is stated before any engagement begins.
What the citation showsThe name of the official register or public filing, the date the record was retrieved, and the access condition applied — no date, no citation. Access conditionEach source entry records whether access required registration, a national identifier, a declaration of legitimate interest, or a fee paid to the registry. What the citation does not showA citation confirms the record was retrieved; it does not confirm the record is complete, current beyond its stated date, or that no parallel filing exists in a different register. When no citation is availableIf no verifiable record exists for a given point, that point is omitted from the report. No inference substitutes for a missing source.Why citation method matters for control analysis
Control is a layered question. Registered ownership, beneficial ownership, and operational authority may sit in different registers, under different access rules, in different languages. A citation that names only one layer without acknowledging the others produces an incomplete picture.
VLO reports assign each factual claim to one of three citation levels:
Level 1 — Confirmed. The record exists in the primary official register, retrieved directly, with a date and access path recorded. Price, term, and access condition are stated exactly as published by the registry.
Level 2 — Probable. The fact is known from a secondary or aggregated source. The claim is generalised: "in the range of" or "approximately." No exact figure is stated at this level.
Level 3 — Mechanism only. The figure or record is not available. The report describes the mechanism — which body holds the record, under what statutory basis, under what access condition — without stating a number.
This three-level structure is applied consistently across all 35 jurisdictions covered. A reader can identify, for every claim, which level applies and therefore what weight to assign it.
How control is traced through official sources
Establishing who controls a company requires crossing at least three source types in most jurisdictions:
Corporate register. The register of companies records legal ownership: shareholders, directors, registered capital, and filed constitutional documents. In most jurisdictions this is the primary source for the formal ownership layer.
Beneficial ownership register. Where a jurisdiction maintains a UBO or PSC register, that register records the natural person who ultimately owns or controls the entity. Access conditions vary significantly. Following the CJEU judgment in joined cases C-37/20 and C-601/20, public access to UBO registers across EU member states is no longer the default. Each jurisdiction's access regime is recorded individually in the source matrix.
Filed financial statements. Where companies are required to file accounts with the register, those filings show the reported financial position at the filing date. They do not show intra-year changes in ownership or control.
Each source is cited with the register name, the retrieval date, and the access path used. Where a source is free of charge and publicly accessible, the report states this. What the engagement covers in that case is the removed path: locating the correct national identifier, navigating language and format, obtaining the record in a form usable outside the jurisdiction.
The limit of what the sources allow
No source citation implies completeness. The following limits apply across the source matrix and are stated in every report where they are relevant.
Registered ownership is not beneficial ownership. A corporate register shows the legal shareholder. Where that shareholder is itself a legal entity, the register does not automatically show who controls that entity. The chain must be traced register by register, jurisdiction by jurisdiction, until it reaches a natural person or an acknowledged break point.
A break point is a result. Where the chain cannot be continued — because a jurisdiction does not maintain a UBO register, because access requires a court order, or because the intermediate entity is in a jurisdiction outside the coverage matrix — the report names the break point and the reason. It does not speculate beyond it.
Absence of a record is not proof of absence. A negative result in an insolvency register confirms that no record was found at the retrieval date under the search parameters applied. It does not confirm that no proceeding has been filed, that no proceeding exists in a parallel register, or that no proceeding will be filed after the retrieval date.
Dates are retrieval dates, not current dates. Every citation carries the date the record was extracted. Corporate registers update continuously. A record retrieved on a given date reflects the state of the register on that date.
Language and format are access conditions. Where a register operates in a non-Latin script or returns records in a format requiring specialist interpretation, the access path is part of the citation. A record retrieved without navigating that path is not a verified citation at Level 1.
Where the sources disagree
Where two sources return conflicting information about the same fact — for example, where the corporate register and the beneficial ownership register record different persons as controlling shareholder — the report presents both records, states the retrieval date of each, and identifies the nature of the discrepancy.
A discrepancy between sources is itself a material finding. It may indicate a filing lag, an unreported transfer, a data entry error, or a structural arrangement that the sources do not fully capture. The report records the discrepancy; it does not resolve it by choosing one source over the other.
Where a discrepancy exists, the report will note which source is the primary legal record in the relevant jurisdiction and which is secondary or derived.
How jurisdiction affects citation
The same fact — for example, the identity of the majority shareholder — may be verifiable at Level 1 in one jurisdiction and only at Level 2 or Level 3 in another. This is not a gap in the analysis; it is the analysis. The source matrix records, for each of the 35 jurisdictions covered, which register exists, what it contains, what the access condition is, and what the known limits are.
Jurisdictions differ on the following dimensions, all of which affect citation level:
- Whether a corporate register is publicly searchable without registration
- Whether beneficial ownership data is held in a register and under what access regime
- Whether filed financial statements are publicly available or require a fee or formal request
- Whether insolvency proceedings are recorded in a searchable public register
- Whether records are returned in a format that can be cited directly or require certified translation
These dimensions are recorded in the source matrix before any report is commissioned. The scope of what can be established — and at what citation level — is known before payment.
FAQ
Why does the report state a citation level rather than simply citing the source? Different sources carry different evidentiary weight. A record retrieved directly from the primary official register on a named date is a different quality of evidence from a record retrieved from an aggregated database. The citation level makes that difference explicit so the reader can assess the claim accordingly.
What happens when a source requires a national identifier to search? Many registers are not searchable by company name alone. They require a national registration number, tax identifier, or similar. Obtaining and applying the correct identifier is part of the retrieval path and is recorded in the citation. Where the identifier cannot be obtained without local registration or formal request, that constraint is noted and the citation level is adjusted accordingly.
Does a Level 1 citation mean the information is correct? A Level 1 citation means the record was retrieved directly from the primary official source on the stated date under the stated access conditions. It does not mean the underlying filing is accurate, that the filing party had an obligation to file correct information, or that the record has not changed since retrieval. Official registers record what was filed; they do not verify it.
What does the report show when the beneficial ownership chain cannot be completed? The report traces the chain to the point where it can be verified from official sources. It names the last verifiable link, the register in which that link appears, and the reason the chain cannot be continued further. That break point is stated as a finding, not as an absence of analysis.
How are free-of-charge registers handled? Where a register is publicly accessible without charge, the report states this. The engagement covers the retrieval path — identifying the correct national identifier, navigating language and format, extracting the record in a usable form, and recording the access conditions applied. The cost of registry access and the cost of the retrieval service are separate items and are not conflated.
Can the same company appear in registers across multiple jurisdictions? Yes. A company incorporated in one jurisdiction may be registered as a foreign branch or subsidiary in others, may file tax records in a third, and may have its beneficial owner recorded in a fourth. Each register is cited separately. The report does not merge records across jurisdictions without stating the basis for the connection.
Sources
No registry-specific sources are cited on this page. Source citations appear within individual jurisdiction reports, each carrying the register name, the official URL of the registry, and the retrieval date. All retrieval dates in VLO reports fall on or before the report publication date.
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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: Elena Moretti — Partner, Continental Europe, VLO Law Firm
