top of page

EU Common Formats for Beneficial Ownership Information

Antonis Hadjicostas
2 days ago
3 min read

What entities in Cyprus need to know


Commission Implementing Regulation (EU) 2026/2354 - A common EU framework for BO submissions


Commission Implementing Regulation (EU) 2026/2354 introduces common formats for submitting beneficial ownership information. Adopted on 16 October 2026 and published in the Official Journal on 22 October 2026, the Regulation applies from 10 July 2027.

The measure harmonises the formats used to submit beneficial ownership (BO) information to central registers across the EU. For entities in Cyprus, it warrants consideration in relation to their own reporting obligations and, where relevant, the information they maintain about client ownership and control.


What the Regulation does

The Regulation establishes common submission formats and minimum acceptance requirements for central registers. Its purpose is to improve data quality, consistency and interoperability. It operates within the wider EU AML framework, including Regulation (EU) 2024/1624 and Directive (EU) 2024/1640; it does not itself redefine who qualifies as a beneficial owner.


The Key Changes


Consistent identification and control information

The formats cover personal identification details, country of residence, nationalities and identity-document information, including the issuing country. They also distinguish direct and indirect ownership and different means of control. Separate formats address trusts and similar arrangements, nominees and nominators, and beneficial interests in collective investment undertakings.


Clearer presentation of ownership structures


Articles 2 and 3 and Annex I address ownership and control information through file uploads or structured data. Organisational charts are a central feature, but the text also accommodates alternative collection methods and proof of dispersed ownership where relevant.

Structured explanations and acceptance requirements


Article 1(6) specifies minimum selectable reasons where a beneficial owner cannot be identified. This should not be treated as a substitute for a properly supported assessment. Article 5 establishes minimum conditions that submissions must satisfy before central registers may accept them.


What this means for entities in Cyprus


The practical significance extends beyond the presentation of a register submission. More consistent information should make ownership records easier to interpret and compare. In our view, this increases the importance of ensuring that the ownership position reflected in an entity’s records can be explained and supported.


The implications will differ according to each organisation’s role. Companies should consider their own BO reporting obligations, where applicable, while firms providing corporate administration, trustee or other relevant services should also assess the effect on the structures they service. Entities subject to AML obligations should consider how register information interacts with their customer due diligence records.


These are related but distinct responsibilities. A register submission and a firm’s assessment of its customer’s ownership and control serve different purposes. Preparation should therefore reflect the organisation’s actual obligations, activities and, where relevant, client profile.


Timing and existing registrations

The application date is 10 July 2027. Recital 10 indicates that existing registrations should not be immediately affected by the new formats and envisages their use when existing information is updated. This does not amount to a blanket requirement to re-file all existing registrations on that date. Further guidance from the relevant Cyprus registers will be important for operational implementation.


The wider AML Regulation also contains obligations concerning the maintenance, verification and updating of BO information. Those obligations should be distinguished from the submission formats introduced by this implementing measure.


Preparing for July 2027


  • Assess the implications for the organisation’s own reporting obligations and, where relevant, the client structures or arrangements it services.

  • Review the completeness and consistency of BO information and supporting records, with particular attention to complex ownership and control arrangements.

  • Consider the procedural, system and staff-awareness changes needed ahead of July 2027, taking account of further guidance from the relevant registers.


ENAH Services Ltd can support organisations in assessing the implications of the new formats and identifying proportionate changes to their BO records, processes and, where applicable, AML framework. Please contact us to discuss how the requirements affect your organisation.


The material reflected in our website, including Blog material, is for informational purposes only and does not constitute legal advice, consulting, or any other professional advice. Please seek independent professional guidance for your specific needs.

​

All rights reserved. No part of this work may be reproduced, stored in a retrieval system of any nature, or transmitted, in any form or by any means including photocopying and recording, without the prior written permission of the ENAH Services Ltd. The reproduction or transmission of all or part of the work, whether by photocopying or storing in any medium by electronic means or otherwise without the written permission of the owner is strictly prohibited and the commission of any unauthorised act in relation to the work will result in civil and/or criminal actions. 

bottom of page