EU Single Format for Declaring Beneficial Ownership: What Companies Must Do in 2026

Key data

If your company, foundation or association is required to declare who holds real control over the entity, the way you declare it has just changed. The Commission Implementing Regulation (EU) 2026/2354, published on 22 October 2026, sets the standardized formats that must be used throughout the European Union to submit information on beneficial ownership within the framework of anti-money laundering (AML) regulations.

Until now, each Member State could have its own models and data structures. With this regulation, the European Commission imposes a single template that facilitates the exchange of information between national registers and the European system BORIS (Business Ownership and Registered Information System, the EU's beneficial ownership register interconnection system).

What does this regulation establish?

Commission Implementing Regulation (EU) 2026/2354 regulates exclusively the format in which information on beneficial ownership must be presented, not who is required to declare it or what information must be included (that is established by the underlying AML regulations). Specifically:

• It sets uniform models for the entire EU that entities must use when submitting their beneficial ownership declarations to national registers.
• It ensures that data is interoperable between the registers of different Member States and the BORIS system.
• It requires entities to review and adapt their internal compliance procedures to ensure that information is presented in the correct format.
• It applies to companies, foundations, associations and other legal entities subject to the obligation to declare beneficial ownership in the EU.
• It also affects intermediaries (notaries, lawyers, tax advisors) who assist their clients in complying with these obligations.

The BORIS system is the central axis of this standardization: it is the European platform that interconnects all national beneficial ownership registers, and it can only function if data arrives in a homogeneous format. This regulation is, in essence, the technical piece that makes that interoperability possible.

Economic and operational impact

The direct impact of this rule is operational and compliance-related, not a new fee or direct tax cost. However, ignoring it has real economic consequences:

• Internal adaptation cost: Companies that already have beneficial ownership declaration procedures will need to review whether their templates, forms and internal systems comply with the new standardized format. This may require time from the compliance team or external advisor.
• Risk of administrative sanctions: Non-compliance with beneficial ownership obligations—including presenting it in the wrong format—may result in sanctions under applicable AML regulations in each Member State. The regulation does not set specific penalty amounts (those are established by national AML legislation), but the risk is real and must be managed.
• Impact on intermediaries: Notaries, lawyers and tax advisors who manage these declarations for their clients will need to update their workflows and documentation to adapt to the new format. The cost will be passed on, in part, to their business clients.
• Long-term efficiency improvement: Standardization reduces friction in cross-border operations within the EU, as beneficial ownership registers from different countries will be directly comparable and interoperable through BORIS.

Who does it affect?

• Companies (capital companies, partnerships, etc.) required to register their beneficial ownership in the corresponding register.
• Foundations subject to AML transparency obligations.
• Associations and other legal entities with an obligation to declare beneficial ownership.
• Notaries who intervene in the incorporation or modification of legal entities.
• Lawyers and legal advisors who advise on AML compliance matters.
• Tax advisors who manage beneficial ownership declarations for their clients.
• Regulatory compliance departments (Compliance) of business groups with presence in several EU countries.
• CFOs and financial directors responsible for regulatory compliance in their organizations.

Practical example

Imagine a Spanish limited liability company with a German majority shareholder who controls 60% of the capital. The company was already required to declare that shareholder as the beneficial owner to the Spanish Commercial Register.

Until now, that declaration was submitted according to the model required by Spanish regulations. With Regulation (EU) 2026/2354, the format of that declaration must be adjusted to the European standardized model, so that when the Spanish Commercial Register shares that information with BORIS—and this makes it available to, for example, a German bank that wants to verify the beneficial ownership of its client—the data is directly readable and interoperable without the need for manual translation or adaptation.

The tax advisor or notary who manages the declaration for this company must ensure that the form they use complies with the new European standard. If the company submits the declaration in an obsolete or incorrect format, it risks the register rejecting it or the obligation being considered unfulfilled, with the consequent risk of administrative sanction.

What should companies do now?

1. Identify whether your entity is required to declare beneficial ownership under applicable AML regulations in your country. If you were already doing so, this regulation directly affects you.
2. Review the current forms and templates you use to submit the beneficial ownership declaration and verify whether they comply with the new European standardized format.
3. Inform your external advisor (notary, lawyer, tax advisor) of this change and ask them to confirm that their working models are already updated to the new standard.
4. Update internal compliance procedures (manuals, checklists, approval flows) to reflect the new mandatory format.
5. Be alert to the entry into force date, which has not been specified in the published text: monitor the EU Official Journal and communications from your national register to learn the exact adaptation deadline.
6. If you are an intermediary (notary, lawyer, tax advisor), update your client assistance models and communicate the change to the entities you advise on AML matters.

Official source

Consult the complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602354