Restrictions on Public Access to Beneficial Ownership Information
Published 25 August 2025
Category: Financial Regulation
Today, 25 August 2025, the Danish Business Authority (DBA) reannounced that effective from 1 September 2025 new restrictions on public access to information regarding beneficial owners in the Danish Business Register (CVR) will be implemented. The restrictions are part of the implementation of the 6th Anti-Money Laundering Directive (“AMLD6”) (Directive (EU) 2024/1640) which is part of the EU’s Anti Money Laundering package covered in our previous update.
The restrictions mark a significant shift from the previous open-access policy, aiming to strike a balance between transparency and the protection of personal data. Under the new regulations, only a limited set of interested parties will be granted access to beneficial ownership information.
Along with the first announcement on 18 June 2025, the DBA published guidelines regarding access to information regarding beneficial owners. Today the guidelines were updated to include FAQ and a miniguide for obligated entities to apply for access.
Who Can Access the Information?
The scope of access is now limited to three key categories:
- Competent Authorities: These include agencies and organizations directly involved in the prevention of money laundering and terrorist financing.
- Obligated Entities: This category encompasses individuals and businesses legally required to comply with anti-money laundering regulations, including managers of alternative investment funds.
- Entities with Legitimate Interest: A broader group that includes journalists, civil society organizations, and third-party data providers.
How to Access the Information
Eligible users can obtain information through lookup on CVR.dk. This requires logging in with MitID and ticking off a solemn declaration confirming that they meet the access criteria. Once these steps are completed, immediate access to the requested information is granted.
For organizations requiring a more integrated solution, the CVR offers an Application Programming Interface (API). This system-to-system interface allows for the retrieval of beneficial ownership information directly through their own systems.
Also tagged ‘Beneficial Ownership’
Danish Parliament Strengthens Registration Requirements of Ultimate Beneficial Owners
On 2 May 2019, the Danish Parliament adopted amendments to the Danish Companies Act, which implements part of the 5th EU Anti-Money Laundering Directive.
Beneficial OwnershipComplianceDanish RegulationDisclosure RequirementsKYC / AMLProposal to Strengthen the Registration of Ultimate Beneficial Owners
On 13 March 2019, the Danish Government presented a proposal for an amendment of various acts including the Danish Companies Act which implements part of the 5th EU Anti-Money Laundering Directive concerning the registration of ultimate beneficial owners.
Beneficial OwnershipComplianceDanish RegulationDisclosure RequirementsKYC / AMLEU Court of Justice Issues Ruling in Danish Beneficial Ownership Cases
The CJEU judgments will likely have a big impact on international group structures and will also contribute to the interpretation of the anti-abuse principles of EU law and the "beneficial owner" concept.
Beneficial OwnershipDanish RegulationOther updates
Proposed amendments to section 7p of the Danish Tax Assessment Act
On 26 August 2025, a draft bill regarding amendments to section 7p of the Danish Tax Assessment Act was submitted for consultation.
Venture CapitalESMA Report: Improvements needed in the supervision of sustainability risks and disclosures
The report presents ESMA’s analysis and key findings from the CSA, along with its overall assessment of market participants’ adherence to applicable rules and standards.
ESMASFDRSustainabilityDanish implementation of AIFMD II adopted
On 11 June 2025, the Danish Parliament adopted the bill (L 193B) for implementing the AIFM Directive II into Danish law.
AIFMDAIFMD reviewCross-BorderDanish RegulationRisk ManagementProposal on Danish implementation of AIFMD II
On 9 April 2025, the Danish Government presented a proposal for amendments in the Danish financial regulation, including the Danish Alternative Investment Fund Managers (“AIFM”) Act.
AIFMDAIFMD reviewCross-BorderDanish RegulationRisk ManagementMain recommendations from the report on advancing sustainable finance
The work performed by the Platform on Sustainable Finance has focused on developing technical criteria for new economic activities and reviewing activities included in the Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852.
SustainabilityThematic review of engagement information
The Danish Financial Supervisory Authority (the “DFSA”) has conducted a thematic review of six pension companies and investment managers and their engagement information (active ownership).
SFDRSustainability