An ownership structure report maps who holds registered shares, who sits on the board, and what the filed capital structure shows. These are facts drawn from official registers. Whether those facts can be placed before a court — and what weight they carry — depends on the procedural rules of the forum, not on the content of the report itself.
Control is the operative question. A shareholder with a registered majority stake holds a position that appears in the official record. That record is the starting point for any enforcement action, shareholder dispute, or cross-border insolvency proceeding. The gap between what the register shows and who actually exercises control is where disputes begin.
Company registers record the legal layer of ownership: named shareholders, percentage stakes, director appointments, and filed constitutional documents. In most jurisdictions, a certified extract from the register is a public document. Courts treat public documents as presumptively authentic.
The practical consequence: a certified extract does not need a witness to establish its existence. It establishes itself. What it does not establish is whether the named shareholder acts on their own account or on instructions from another party.
Registers across 35 jurisdictions differ in three material respects:
| Dimension | Range across jurisdictions |
|---|---|
| Shareholder disclosure | Named individuals (most EU registries) to registered agent only (certain offshore structures) |
| Update frequency | Real-time filing (UK Companies House) to annual update cycles |
| UBO layer | Separate mandatory register (UK PSC, Poland CRBR) to no public UBO disclosure (post-CJEU C-37/20 default across EU) |
| Document format | Structured data with API access to scanned paper filings only |
| Access condition | Open and free to registration plus legitimate interest declaration |
No single register covers all layers. A report that maps the registered layer across multiple jurisdictions identifies exactly where the chain is visible and where it is not.
Courts in civil-law systems admit official register extracts as public documents under their civil procedure codes. The extract proves that the register contains the stated entry on the stated date. It does not prove that the entry is accurate — only that it was filed.
In common-law systems, the same extract is admissible as a business record or official document under the relevant evidence rules. Authentication is required: the document must come from the register directly or through a certified channel. A printout from a commercial database is not the same as a certified extract from the registrar.
Three procedural points matter for cross-border use:
Apostille or legalisation. A register extract used in a foreign court typically requires an Apostille under the 1961 Hague Convention, or full legalisation if the issuing jurisdiction is not a Convention signatory. The requirement is set by the forum court, not by the issuing register.
Translation. Most courts require a certified translation into the language of the proceedings. The translation must be certified by a sworn translator recognised in the forum jurisdiction.
Currency of the extract. Courts often require that the extract be recent — commonly within 30 to 90 days of the hearing date. An extract obtained for due diligence six months earlier may not satisfy the currency requirement at trial.
A report compiled from official sources can be structured to meet these requirements from the outset, rather than requiring supplementary authentication after the fact.
The registered record shows legal ownership. Control — the ability to direct the company's decisions — may sit elsewhere. Three structural patterns produce this gap:
Nominee arrangements. A registered shareholder holds shares on behalf of an undisclosed principal. The register shows the nominee. The beneficial owner does not appear unless the jurisdiction requires separate UBO disclosure.
Layered holding structures. The registered shareholder is a holding company in another jurisdiction. That holding company has its own shareholders, who may themselves be holding companies. Each layer requires a separate registry query in a separate jurisdiction.
Voting agreements and shareholder agreements. Filed constitutional documents may not reflect side agreements that allocate voting control differently from the registered shareholding. These agreements are typically not filed in any public register.
A report that maps the registered chain across all layers identifies the point at which the chain becomes opaque. That identification is itself a result: it establishes what the official record shows and where it stops.
Official registers record what was filed. They do not verify that what was filed is accurate. A shareholder list reflects the position as of the last filed update, not necessarily the current position.
Specific limits that apply across the 35-jurisdiction coverage:
UBO registers in the EU. Following the CJEU judgment in Case C-37/20, public access to beneficial ownership registers is no longer the default across EU member states. Access requires a demonstrated legitimate interest in most jurisdictions. The registered shareholder layer remains accessible; the UBO layer does not.
Delaware and similar structures. LLC membership in Delaware is not recorded in any public register. The registered agent is the only public entry. The ownership layer requires operating agreements, which are private documents.
Offshore jurisdictions. Several jurisdictions within the 35-jurisdiction coverage maintain registers that record only the registered agent or the corporate secretary, not the ultimate shareholders. The registered layer in these jurisdictions is a single entry that does not identify any natural person.
Timing gaps. In jurisdictions with annual filing cycles, the register may reflect a position that is 11 months old. A transaction completed after the last annual filing will not appear.
Insolvency registers. A negative result in an insolvency register does not confirm the absence of a filed petition. Filing and registration are separate steps; the gap between them varies by jurisdiction.
The ceiling of what the sources allow is stated before payment. A report does not promise to establish what the sources cannot show. It establishes what they do show and names the point at which the chain stops.
Discrepancies between sources are a result, not a gap. Three common patterns:
Register versus filed accounts. The shareholder list in the company register names one set of owners. The consolidated accounts filed with the same register show a different group company as the parent. The discrepancy identifies a structural question that the register alone cannot resolve.
Multiple jurisdictions, inconsistent entries. A holding company registered in jurisdiction A lists subsidiary X as wholly owned. The register in jurisdiction B shows subsidiary X with a different shareholder. One entry is outdated; the other may reflect a transaction that was filed in one jurisdiction but not yet in the other.
Register versus court record. A judgment creditor has registered a charging order against shares. The company register still shows the debtor as the registered shareholder. The court record and the company register tell different stories about the same asset.
Each discrepancy is documented in the report with the source, the date of extraction, and the nature of the conflict.
Does a register extract prove that a person controls a company? A register extract proves that a person is recorded as a shareholder or director as of the date of the extract. Control — the actual exercise of decision-making authority — is not recorded in any register. The extract establishes the legal layer; control analysis requires additional sources.
What authentication is required to use a register extract in foreign proceedings? The requirement is set by the forum court. In Hague Convention jurisdictions, an Apostille issued by the competent authority of the issuing state is the standard route. In non-Convention jurisdictions, full legalisation through the consular chain is required. Certified translation into the language of the proceedings is a separate requirement in most forums.
Can a report cover a multi-layer holding structure across several jurisdictions? A report can map the registered chain across all jurisdictions in which entities in the structure are incorporated. Each layer requires a separate registry query. The report identifies the point at which the chain becomes opaque — where a jurisdiction does not disclose shareholders, or where a layer is held through a structure that has no public register entry.
What is the difference between a register extract and a report? A register extract is a certified copy of what the register contains. A report compiles, cross-references, and maps extracts from multiple registers, identifies discrepancies, and states the limits of what the sources show. A report is structured for use in proceedings; a raw extract requires additional work to place in context.
How current does the extract need to be for court use? Currency requirements vary by forum. Many courts require an extract dated within 30 to 90 days of the hearing. A report can be structured to include extracts obtained within the required window, with the extraction date recorded for each source.
Sources:
Official company registers across 35 jurisdictions — extracted September–October 2026. Specific register URLs are provided in the delivered report for each jurisdiction covered.
UK Companies House — https://find-and-update.company-information.service.gov.uk — extracted 08.10.2026
Handelsregister (Germany) — https://www.handelsregister.de — extracted 08.10.2026
Poland CRBR (Central Register of Beneficial Owners) — https://crbr.podatki.gov.pl — extracted 08.10.2026
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: Katharina Berg — Partner, Central Europe, VLO Law Firm