A competitor name in a cap table is not a coincidence until the sources say otherwise. The question is not whether the holding is hostile — that is a legal qualification. The question is who controls the entity, who appointed the directors, and how far the ownership chain can be traced before the sources run out.
This report establishes those facts across the official record. It names the directors on the date of extraction, traces the shareholder structure to the layer where disclosure ends, and states explicitly where the chain stops and why.
What the report establishesNamed directors with appointment dates; shareholder of record with percentage held; intermediate holding entities where disclosed. Sources: national company registries across covered jurisdictions · verified September 2026. What the sources do not showNominee arrangements, undisclosed trust structures, and beneficial owners shielded by post-CJEU C-37/20 UBO register restrictions are not visible in the public record. Condition of accessSeveral registries require a national identifier, a declared legitimate interest, or a domestic electronic signature. The report absorbs those access conditions; the client receives the extracted document, not the access path. Price tiersSignal €1,350 · Standard €2,850 · Extended €6,300. Scope defined in the tier table below.What a competitor in the cap table triggers
A competitor holding — even a minority one — can affect board composition, information rights, veto thresholds, and exit mechanics. None of those consequences can be assessed without first knowing who the holder actually is.
The company register shows the shareholder of record. It does not show who instructed that shareholder to acquire the stake, who receives the economic benefit, or whether the registered holder is a nominee. Establishing those facts requires a layered review: the registered entity, its own ownership structure, the directors of each intermediate vehicle, and the filings that disclose changes in control.
The report follows that sequence. Each layer is sourced, dated, and marked with the level of certainty the source supports.
The director layer: what the register shows
Company registries in most jurisdictions maintain a current list of directors with appointment and, where applicable, resignation dates. The report extracts:
- Full legal name of each director on the date of extraction
- Date of appointment
- Any concurrent directorships filed in the same registry
- Resignation history where the registry retains it
Concurrent directorships are material. A director who sits on the board of both the target company and the competitor entity is a structural connection that the register documents directly.
The registry record does not show whether a director acts on instructions from a particular shareholder. That inference is a legal qualification and falls outside this report.
The shareholder layer: registered holders and intermediate vehicles
The shareholder of record is the entity or individual named in the company's filed ownership documents. Where the holder is itself a legal entity, the report traces one further layer: the ownership structure of that intermediate vehicle, using the registry of its jurisdiction of incorporation.
This produces a chain of the form: Target → Registered holder → Owner of registered holder. Each link is sourced from the relevant national registry.
The chain stops at the layer where the registry does not disclose further ownership. That stopping point is stated explicitly in the report, with the reason: registry policy, post-CJEU UBO restriction, jurisdiction that does not maintain a public shareholder register, or a structure that files no ownership documents.
| Layer | What is extracted | Source type |
|---|---|---|
| Target company | Directors, shareholders of record, filing history | National company registry |
| Intermediate holding entity | Directors, shareholders of record | Registry of incorporation jurisdiction |
| Second-level intermediate | Directors where disclosed | Registry of incorporation jurisdiction |
| UBO register | Beneficial owner where public access is available | National UBO or PSC register |
| Insolvency register | Any open or closed proceedings | National insolvency register |
UBO registers after CJEU C-37/20
The Court of Justice ruling in C-37/20 removed the general public access obligation from EU member-state UBO registers. Access now requires a demonstrated legitimate interest in most EU jurisdictions. The practical effect: a foreign requester without a domestic identifier or a recognised interest category cannot retrieve UBO data directly from most EU registers.
The report addresses this in two ways. Where a legitimate interest pathway exists and the facts of the instruction support it, the report pursues that pathway. Where no pathway is available, the report states the restriction, names the register, and describes what the register would show if access were granted — so the client understands what is missing and why.
The United Kingdom PSC register and the Polish CRBR retain broader access. Both are covered in the Extended tier. Access conditions for both are verified before the report is issued; the regime for each is subject to confirmation by local counsel before any SKU is opened on beneficial ownership.
Filing history and changes in control
A single-point extract of the current register misses the sequence. A competitor may have acquired the stake through a series of transfers, each of which was filed separately. The report reviews the filing history for:
- Share transfer notifications filed in the relevant period
- Changes in director appointments coinciding with ownership changes
- Any filed shareholders' agreements or consent documents where the registry retains them
The filing history is available in most registries for a defined retention period. Where the registry does not retain historical filings, the report states the retention limit and the date from which the record is complete.
Cross-jurisdictional coverage
The competitor entity may be incorporated in a different jurisdiction from the target. The intermediate holding vehicle may be in a third. The report covers the registries of each relevant jurisdiction in the chain, up to the tier limit.
Coverage across 35 jurisdictions means the report does not stop at the first registry. It follows the chain into the jurisdiction of each intermediate entity and extracts what that registry shows.
Where a jurisdiction does not maintain a public company register, or where the register is not accessible to foreign requesters without conditions the instruction cannot satisfy, the report names the jurisdiction, describes the gap, and states what would be required to fill it.
The limit of what the sources allow
Official registries show what was filed. They do not verify what was true at the time of filing. A nominee arrangement is not visible in the register unless it was disclosed. A trust structure holding shares through a registered entity does not appear in the shareholder list. A side agreement between shareholders is not a registry document.
The following categories are outside the scope of what the sources allow:
- Undisclosed nominee relationships between the registered holder and a third party
- Beneficial ownership shielded by EU UBO access restrictions where no legitimate interest pathway applies
- Shareholdings held through bearer instruments in jurisdictions that still permit them
- Oral or unregistered agreements affecting control
- Economic interests held through derivative instruments not filed with a registry
The report states, for each jurisdiction in the chain, which of these categories applies and what the registry would show if the restriction were lifted. The ceiling of what the sources allow is stated before payment.
Where the sources disagree
A registry extract and a filed annual return may show different shareholder percentages for the same period. A director listed as current in the company register may appear as resigned in a cross-border filing. These discrepancies are not errors to be smoothed over — they are findings.
The report flags every discrepancy between sources, states the date of each conflicting record, and identifies which source is the authoritative filing for the jurisdiction. The discrepancy itself is a result: it indicates either a filing delay, an administrative error, or a structural inconsistency that warrants further review.
Scope and fixed price
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €1,350 | Current directors with appointment dates; shareholder of record with percentage; one intermediate holding entity traced; insolvency register check in the primary jurisdiction; source-dated extract for each finding | Second-level intermediate entities; UBO register access; filing history review; cross-jurisdictional coverage beyond primary and one intermediate jurisdiction |
| Standard | €2,850 | Everything in Signal; second-level intermediate entity traced; filing history review for the relevant period in each covered registry; concurrent directorship check across covered jurisdictions; discrepancy flagging between sources; UBO register access where a legitimate interest pathway applies | Bearer instrument jurisdictions where no registry access is available; jurisdictions where the register is not accessible to foreign requesters without unsatisfiable conditions; legal qualification of findings |
| Extended | €6,300 | Everything in Standard; full chain traced to the layer where the source stops, with explicit statement of the stopping point and reason; UK PSC and Polish CRBR access where applicable; coverage across all jurisdictions in the chain up to 35; insolvency register check in each covered jurisdiction; discrepancy analysis with source-authority determination; written statement of what each inaccessible register would show if access were granted | Oral or unregistered agreements; derivative instrument holdings not filed with a registry; legal advice on the implications of findings; representation in any proceeding |
FAQ
Why does the report cover intermediate holding entities rather than stopping at the registered shareholder? The registered shareholder is often a holding vehicle with its own ownership structure. Stopping there leaves the chain incomplete. The report traces each intermediate entity to the layer the sources support, because the competitor's control may be exercised through a vehicle that does not appear in the target's own register.
What happens when a UBO register requires a legitimate interest declaration? The report assesses whether the facts of the instruction support a recognised interest category in the relevant jurisdiction. Where they do, the declaration is prepared and submitted. Where they do not, the report states the restriction, names the register, and describes what it would show — so the gap is documented rather than ignored.
Does the report cover jurisdictions where the company register is not public? Where a register is not accessible to foreign requesters, the report names the jurisdiction, states the access condition that cannot be satisfied, and describes the mechanism by which the information could be obtained. The gap is a finding, not an omission.
What does the filing history review cover? The review covers share transfer notifications, director appointment and resignation filings, and any consent documents or shareholders' agreement summaries filed in the registry for the relevant period. The retention period varies by jurisdiction; the report states the date from which the record is complete.
Can the report establish whether a director acts on instructions from the competitor? No. The register shows who the director is and when they were appointed. Whether they act on instructions from a particular shareholder is a factual and legal question that requires evidence beyond the registry record. That inference is outside the scope of this report.
What is the difference between Signal and Standard for a simple two-layer structure? If the chain has only two layers — target and one intermediate — Signal covers it fully. Standard adds value when the intermediate entity is itself held by another vehicle, when filing history is material, or when concurrent directorships across jurisdictions are relevant to the analysis.
Sources:
- National company registries — accessed per jurisdiction; official registry portals used for each covered jurisdiction · extracted September–October 2026
- EU UBO registers — accessed where public access or legitimate interest pathway is available; regime confirmed per jurisdiction · verified October 2026
- UK Companies House PSC register — https://find-and-update.company-information.service.gov.uk · extracted October 2026
- Polish Central Register of Beneficial Owners (CRBR) — https://crbr.podatki.gov.pl · extracted October 2026
- National insolvency registers — accessed per jurisdiction · extracted September–October 2026
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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
