The question of who controls a company has two distinct answers. One answer names the directors on the register. The other traces the ownership chain to the person who ultimately holds the economic interest. These are not the same question, and the sources that answer each one are different.
This page describes what each tier of the director and beneficial owner report covers, which sources are used at each tier, and where the analysis stops. The ceiling of what the sources allow is stated before payment.
The tier structure exists because the depth of a director and beneficial owner analysis is not uniform across jurisdictions. A single-jurisdiction query on a straightforward structure requires less work than a multi-layer chain spanning holding companies in several countries. The three tiers — Signal, Standard, Extended — reflect that difference in scope, not a difference in quality.
Each tier answers the same core question: who controls this entity, and what can a shareholder enforce. The difference is how far the chain is traced and how many sources are queried.
The Signal tier establishes what the corporate register shows on the date of extraction.
For directors, this means: names, appointment dates, and any recorded cessation of office. For shareholders, this means: names and shareholding percentages as filed. Where a jurisdiction requires a separate beneficial ownership register, the Signal tier queries that register and records what it returns.
The Signal tier does not trace holding companies. If a shareholder is itself a legal entity, the Signal tier names that entity and stops. It does not open the next layer.
This tier is appropriate when the counterparty is a single-jurisdiction entity with a straightforward ownership structure, and when the purpose is to confirm the registered position rather than to map control.
The Standard tier extends the analysis to the immediate holding layer. Where a corporate shareholder appears at the first level, the Standard tier queries the register of that shareholder's jurisdiction and records what it returns.
For beneficial ownership, the Standard tier applies the threshold used by the relevant register — typically a defined percentage of shares or voting rights — and identifies any person recorded above that threshold. Where the register returns no result, that outcome is recorded and the reason is stated.
The Standard tier also queries insolvency and enforcement registers in the primary jurisdiction. A negative result is recorded as such; it does not certify absence of proceedings filed in a jurisdiction not queried.
This tier is appropriate for cross-border transactions where the immediate holding structure is known but the registered position of each entity needs to be confirmed from primary sources.
The Extended tier traces the ownership chain through multiple layers, across multiple jurisdictions, until it reaches either a natural person recorded in an official source or a layer at which no further official source is available.
At each layer, the Extended tier records:
The Extended tier also compares the director and shareholder position across sources. Where the corporate register, the beneficial ownership register, and filed financial statements show different persons or different percentages, that divergence is recorded as a finding. A divergence between sources is itself a result.
The Extended tier does not interpret the legal significance of what the sources show. It records what each source says and where the sources disagree.
| Tier | Director register query | Shareholder register query | Beneficial ownership register query | Holding layer trace | Insolvency register query | Divergence analysis |
|---|---|---|---|---|---|---|
| Signal | Primary jurisdiction | Primary jurisdiction | Primary jurisdiction (where available) | No | No | No |
| Standard | Primary + immediate holding jurisdiction | Primary + immediate holding jurisdiction | Primary + immediate holding jurisdiction | One layer | Primary jurisdiction | No |
| Extended | All identified layers | All identified layers | All identified layers | Multi-layer to source ceiling | All identified jurisdictions | Yes |
Official registers record what has been filed. They do not record what has not been disclosed.
A director register shows who has been appointed and who has not been removed. It does not show who gives instructions to the director. A shareholder register shows who holds shares on the register. It does not show who holds the economic benefit under a side agreement. A beneficial ownership register shows who has been declared above the filing threshold. It does not show arrangements structured to remain below that threshold.
In several EU jurisdictions, public access to beneficial ownership registers is restricted following the 2022 CJEU ruling in Case C-37/20. Where access is restricted, the Extended tier records the restriction and states what alternative sources were queried. No tier claims to circumvent a legal access restriction.
Nominee arrangements are not visible in any official register unless the nominee has been required to file a declaration. Trust layers are not recorded in corporate registers. Discretionary powers held outside the share register are not recorded anywhere.
The Extended tier traces the chain to the layer the sources allow. It names the layer at which the chain stops and states the reason. That is the ceiling of the analysis.
Where different official sources return different information about the same person or the same entity, the Extended tier records both results and identifies the source of each. Common divergences include:
A divergence between sources does not establish which source is correct. It establishes that the sources disagree and identifies the date of each record. That finding is delivered as part of the report.
What does the Signal tier return if the company has a corporate shareholder? The Signal tier names the corporate shareholder and records its jurisdiction and registered number. It does not open the register of that shareholder's jurisdiction. That step is part of the Standard and Extended tiers.
Does a negative result in the insolvency register mean no proceedings exist? A negative result means no record was found in the register queried on the date of extraction. Insolvency registers do not always reflect proceedings filed in other jurisdictions or proceedings filed but not yet recorded. The report states which registers were queried and on which date.
What happens when a beneficial ownership register is not publicly accessible? The report records that the register exists, that access was restricted, and the legal basis for the restriction. Where alternative sources — such as filed financial statements or court records — are available and relevant, those are queried and the results are recorded.
Is the scope of the report fixed before payment? Yes. The tier description defines which sources are queried and which layers are traced. The ceiling of the analysis is stated in the tier description. No additional sources are added after payment without a separate instruction.
Can the report cover a company in any jurisdiction? The report covers jurisdictions where official registers are accessible to foreign requesters, directly or through a declared legitimate interest procedure. Where a jurisdiction is not covered, that is stated before a request is accepted.
Sources
Official corporate registers, beneficial ownership registers, insolvency registers, and filed financial statements in the jurisdictions covered by each tier. Specific register names and URLs are provided in the report delivered to the requester. No registry facts were available for this page row; exact tariffs and fees for register access are not stated here.
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