Record
General

Director and ubo: How the price is set

Who controls the company and what the shareholder can enforce — these two questions define the scope of every director and UBO report. The price follows the scope. It is fixed before payment, stated in full, and does not change after a request is submitted.

The angle is control: who holds it, through which structure, and what the official record shows at each layer. That question is answered differently depending on the jurisdiction, the registry tier, and the document set available. The price reflects those differences directly.

What the report establishesNamed directors, registered shareholders, and the beneficial owner chain to the layer where the official record ends. Source: official company registries and UBO registers by jurisdiction · verified 2026-09-27 Price structureFixed per report, stated before payment. Three tiers: Signal, Standard, Extended. Tier determines depth of source coverage, not jurisdiction count. Access conditionNo registry access is required from the client. The firm handles registration, national identifier, language, and any declaration of legitimate interest. What the report does not establishBeneficial ownership where the register is closed or restricted by court order. The report names the layer at which the chain ends and states the reason.

What determines the price of a director and UBO report

Three variables set the price: the number of jurisdictions, the registry tier in each jurisdiction, and the verification layer required.

Jurisdiction count. A single-entity object in one jurisdiction is the base case. A holding structure spanning five or more jurisdictions multiplies the source work proportionally. Each jurisdiction has its own registry, its own access conditions, and its own document language.

Registry tier. Registries operate at different levels of disclosure. Some return director names and shareholder lists on a public search. Others require a registered account, a national identifier, or a formal declaration of legitimate interest. The tier determines the time and procedural cost of extraction, not only the registry fee.

Verification layer. Signal tier covers the registry record as filed. Standard tier cross-references the registry against filed financial statements and any insolvency or enforcement records available in that jurisdiction. Extended tier adds a document-level review of constitutional documents, share transfer history, and any discrepancies between the registry and the filed accounts.

The price is fixed at the tier level. It does not vary by the result of the search.


What each tier covers

Tier What is included Not included
Signal Named directors and registered shareholders as filed; registry extract with source and date Cross-reference against financial statements; insolvency check; UBO chain beyond the registered layer
Standard Signal content plus filed financial statements (where available); insolvency and enforcement register check; UBO chain to the layer the register discloses Document-level review of constitutional documents; share transfer history; discrepancies analysis
Extended Standard content plus constitutional document review; share transfer history where filed; discrepancies analysis between registry and accounts; written summary of where the chain ends and why Legal qualification of findings; advice on enforcement options; representation

Price tiers are stated in the request response. The scope of each tier is fixed before payment.


The director record: what the sources show

The director record is the most consistently available layer across jurisdictions. Most company registries disclose current directors by name, appointment date, and in many cases the registered address used for service.

What the director record does not show: whether the director acts on instruction, who appointed them, and whether a parallel management structure operates outside the registered layer. These questions are outside the scope of any registry source.

The report states what the registry shows. It does not qualify what the director's role means in practice.


The UBO record: where the chain ends

Beneficial ownership disclosure varies more than any other registry layer. Several patterns recur across the 35 jurisdictions covered:

  • The register is public and searchable without restriction.
  • The register requires a declaration of legitimate interest before access is granted.
  • The register is restricted following a court ruling on privacy grounds.
  • No UBO register exists; beneficial ownership is disclosed only in filed accounts, if at all.

In each case, the report states which pattern applies, what the register returned, and at which layer the chain ends. A closed register is a result. It is reported as such.

The CJEU ruling in joined cases C-37/20 and C-601/20 restricted public access to UBO registers across EU member states as a default. Several member states have implemented access-on-request regimes. The report covers the access condition that applied at the time of extraction.


The shareholder record: registered versus beneficial

The registered shareholder is the person or entity named in the company register or the shareholders' list filed with the registry. The beneficial owner is the natural person who ultimately controls or benefits from the shareholding.

These two records do not always match. A nominee shareholder arrangement, a trust, or a multi-layer holding structure can separate the registered and beneficial layers entirely.

The report covers both layers to the extent the sources allow. Where they diverge, the divergence is stated. Where the beneficial layer is not accessible from official sources, the report names the registered layer and states that the beneficial layer could not be confirmed from available records.


The limit of what the sources allow

The ceiling of what the sources allow is stated before payment. This is not a qualification added after delivery. It is part of the scope definition at the time of the request.

Specific limits that apply across the covered jurisdictions:

Closed UBO registers. Where a register is restricted by court order or national implementation of post-CJEU rules, the beneficial owner cannot be confirmed from that source. The report states this explicitly.

Nominee arrangements. A nominee director or shareholder appears in the registry as the named party. The registry does not flag the arrangement as a nominee. The report cannot confirm a nominee arrangement from registry sources alone.

Unregistered changes. A director resignation or share transfer that has not yet been filed with the registry will not appear in the extract. The report reflects the state of the registry at the date of extraction, not the current factual position.

No structured data. Several registries return documents as scanned images or PDFs without structured fields. Extraction from these sources is manual. The report notes the format of the source document.

Insolvency timing. A negative result in an insolvency register does not confirm that no application has been filed. Filing and registration are not simultaneous in all jurisdictions.

These limits are not failures of the report. They are the boundary conditions of the official record. Knowing where the record ends is itself a result.


Where the sources disagree

When the registry record and the filed financial statements return different information about directors, shareholders, or ownership structure, the discrepancy is reported as a finding, not resolved editorially.

Common patterns of disagreement:

  • A director named in the accounts is not listed in the current registry extract.
  • A shareholder's stake in the accounts differs from the shareholders' list filed with the registry.
  • The UBO register names a natural person; the registry names a corporate entity at the same layer.

Each discrepancy is documented with the source, the date of extraction, and the specific field where the values differ. The report does not determine which record is correct. That determination requires legal analysis, which is outside the scope of this product.


FAQ

Why is the price fixed before the search begins? The scope of the report is defined by the tier, not by the result. The sources to be consulted, the jurisdictions to be covered, and the verification layer to be applied are all known before the search starts. The price reflects the work, not the outcome.

What happens if a registry is inaccessible at the time of the search? The report states that the registry was inaccessible, gives the reason where it is known, and notes the date of the attempt. No substitution is made from secondary sources without disclosure.

Does the price change if the structure is more complex than expected? The price is fixed at the tier level for the object as described at the time of the request. If the object turns out to involve additional jurisdictions not identified at the outset, a revised scope is agreed before additional work proceeds.

Is the beneficial owner always identifiable from official sources? No. In a significant number of jurisdictions and structures, the beneficial owner cannot be confirmed from official sources alone. The report states the layer at which the chain ends and the reason it ends there.

What is the difference between Signal and Extended for a single-jurisdiction object? Signal returns the registry record as filed. Extended adds constitutional documents, share transfer history, and a written analysis of any discrepancy between the registry and the filed accounts. For a simple single-shareholder structure, the difference may be minimal. For a structure with multiple share classes or a history of transfers, it is material.

Can the report be used in legal proceedings? The report is a factual compilation from official sources. It is not a legal opinion and does not constitute legal advice. Whether it is admissible or useful in a specific proceeding is a question for the legal adviser handling that proceeding.


Sources

Official company registries and UBO registers by jurisdiction — accessed per request at the time of extraction · verified 2026-09-27

Insolvency and enforcement registers by jurisdiction — accessed per request at the time of extraction · verified 2026-09-27

Filed financial statements via national filing portals by jurisdiction — accessed per request at the time of extraction · verified 2026-09-27


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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: Katharina Berg — Partner, Central Europe, VLO Law Firm