A director and beneficial owner report establishes who holds formal authority over a company and who holds economic interest in it. These are two distinct questions. The answer to each comes from a different layer of official sources. The ceiling of what those sources allow is stated before payment — not after.
Control is the angle. The report does not assess whether a structure is efficient or compliant. It maps who signs, who owns, and where the chain of ownership stops being visible.
What the report establishesNamed directors, their appointment dates, and registered authority. Named shareholders or members with recorded ownership percentages. Beneficial owner entries where the relevant register makes them accessible. Source layerCommercial registries, official gazette filings, and UBO registers — jurisdiction by jurisdiction. No single global source covers all 35 jurisdictions in scope. Condition of accessSeveral registers require a national identifier, a declared legitimate interest, or a registered account. That path is removed for the client. The report delivers the extracted record, not instructions for obtaining it. What the report does not establishInformal control arrangements, nominee relationships not recorded in a register, and beneficial ownership in jurisdictions where the register is closed or restricted by court order.What the report covers
The report is built from three source layers.
Layer one — the commercial registry. This is the primary source for directors and, in most jurisdictions, for shareholders. It records appointments, resignations, registered address, and — where the jurisdiction requires it — the list of members or shareholders with their ownership percentages. The registry entry is the authoritative public record of formal authority.
Layer two — filed financial statements and gazette notices. Where a company is required to file annual accounts or publish certain changes, those filings provide a secondary check on the registry entry. Discrepancies between the two are noted in the report as a finding, not resolved by assumption.
Layer three — the beneficial owner register. Access conditions vary sharply across jurisdictions. In some, the register is open and searchable without registration. In others, access requires a declared legitimate interest, a national identifier, or both. In EU jurisdictions, the default public access model was restricted following the CJEU ruling in Case C-37/20; the report notes the access regime applicable at the time of extraction.
The report does not combine or reconcile these layers into a single narrative conclusion. It presents what each layer shows, where each layer stops, and what the gap between them is.
Scope across 35 jurisdictions
The report covers up to 35 jurisdictions in a single instruction. Each jurisdiction is treated as a separate extraction task. The source, the access condition, and the data limit are recorded individually for each.
| Element | What is recorded |
|---|---|
| Director | Full name, appointment date, registered authority, resignation date if filed |
| Shareholder / member | Name, ownership percentage, date of last recorded change |
| Beneficial owner | Name and ownership threshold as recorded in the UBO register, or a statement that the register is inaccessible |
| Source | Registry name, official URL, date of extraction |
| Data limit | Explicit statement of what the source does not show |
The report does not produce a single consolidated ownership chart. It produces a jurisdiction-by-jurisdiction record. If a consolidated chart is required, that is a separate analytical step performed after the report is delivered.
The limit of what the sources allow
Every report includes an explicit statement of the ceiling before payment is made. This section describes the structural limits that apply across the coverage range.
Nominee arrangements. A nominee director or shareholder appears in the register under their own name. The register does not record the underlying principal. The report identifies the registered name. It does not infer or assert a nominee relationship unless a separate declaration is filed and accessible.
Closed UBO registers. Following the CJEU ruling in Case C-37/20, EU member states are not required to provide unrestricted public access to beneficial owner registers. Access conditions differ by member state and have changed since the ruling. The report states the access regime in force at the date of extraction. Where access was not possible, the report records that fact explicitly.
Delaware and comparable jurisdictions. Several jurisdictions — including Delaware — do not require disclosure of LLC members in the public registry. The registry record shows the registered agent and the formation date. It does not show ownership. The report records what the registry shows and states the limit.
Insolvency registers. A negative result in an insolvency register does not confirm the absence of a filed petition. Processing delays and jurisdictional gaps mean the register may not yet reflect a recently filed application. The report records the result of the search and notes this structural limit.
Structured data. Some registries deliver records as scanned documents or PDFs without machine-readable fields. The report extracts the relevant information from those documents. It does not convert them into structured data formats.
Where the sources disagree
When the registry entry and a filed document show different information — a director listed as current in the registry but absent from a recently filed annual return, or a shareholder percentage that differs between the membership list and the accounts — the report records both entries and identifies the discrepancy.
A discrepancy is a finding. The report does not resolve it by choosing one source over the other. It presents both, notes the date of each, and states which source is the primary registry record.
This section is included in the report only when a discrepancy exists. It is not a standard narrative section. Its presence is itself informative.
How the report is structured
The report is delivered as a PDF document. It is organised by jurisdiction. Each jurisdiction section contains:
- The source registry, its official URL, and the date of extraction
- The director record as extracted
- The shareholder or member record as extracted
- The beneficial owner record as extracted, or a statement of inaccessibility
- A data limit statement specific to that jurisdiction
A cover page lists the jurisdictions covered, the date of delivery, and the instruction reference. A summary table at the front lists each jurisdiction and the access result for each of the three source layers.
The report does not contain legal advice. It does not contain a qualification of the facts established. It contains extracted records, source citations, and explicit statements of what the sources do not show.
Delivery timeline
The timeline depends on the number of jurisdictions and the access conditions of the registers involved. Jurisdictions where the registry is open and machine-readable are faster. Jurisdictions requiring a declared legitimate interest, a national identifier, or a manual request to a registry office take longer.
A timeline estimate is provided after the instruction is received and the jurisdiction list is confirmed. The estimate is stated as a range, not a fixed date. It reflects the access conditions known at the time of instruction.
Rush delivery is available for a subset of jurisdictions. It is not available where the registry itself imposes a minimum processing period.
FAQ
Does the report cover all 35 jurisdictions in a single document? Yes. The report is delivered as a single document covering each jurisdiction in a separate section. The source, the extraction date, and the data limit are recorded individually for each jurisdiction.
What happens if a UBO register is inaccessible? The report records the inaccessibility explicitly. It states the access regime in force at the date of extraction and the reason access was not possible. This is a finding, not a gap in the report.
Is the report updated automatically? No. The report reflects the state of the registers at the date of extraction. Register entries change. A new instruction is required to obtain a current record.
What is the difference between a director record and a beneficial owner record? A director record shows who holds formal authority to act on behalf of the company. A beneficial owner record shows who holds economic interest above the threshold set by the applicable register. These are separate questions answered from separate sources. A person may appear in one record and not the other.
Can the report be used as evidence in proceedings? The report is a factual compilation from official sources. Whether it is admissible or sufficient for a particular purpose in a particular jurisdiction is a legal question. The report does not address that question. For advice on admissibility, contact info@vlolawfirm.com.
Is the price fixed before the report is commissioned? Yes. The scope and price are confirmed before the instruction is accepted. The ceiling of what the sources allow is stated at the same time. There are no additions after delivery.
Sources
VLO Law Firm draws on official commercial registries, gazette databases, and UBO registers in each jurisdiction covered. Registry names and URLs are recorded in the delivered report against each extraction. No single consolidated source list applies across all 35 jurisdictions; the source citation is jurisdiction-specific and dated.
For questions about source availability in a specific jurisdiction, contact info@vlolawfirm.com.
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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
