UBO thresholds by country, compared
A comparison of beneficial-ownership disclosure thresholds across the EU, UK, US, Switzerland, UAE, Singapore, India and more.
- The 25% threshold is common but far from universal.
- The US CTA now applies only to foreign entities after the 2025 rule change.
- Cross-border families face a patchwork that a single-threshold tool cannot handle.
The patchwork
There is no single global threshold. The EU uses 25% (with a possible 15% for high-risk sectors), the UK 25%, India 10%, South Africa 5%. Switzerland's LETA regime is aligning to a central register. The UAE, Singapore and others each have their own rules and registers.
The US reversal
The US Corporate Transparency Act reversed sharply. A FinCEN interim rule from March 2025 exempts US-formed companies and their owners; only foreign entities registered in a US state now report, and they report no US persons. Any guidance written before that overstates the US obligation.
Why it matters for family offices
A single cross-border family may touch a dozen jurisdictions through its structures. Assessing each beneficial owner against the wrong country's rule is a compliance failure. This is precisely what a jurisdiction-aware engine solves.
FAQ
- EU AMLR 2024/1624 — 25% EU threshold from 2027.
- FinCEN interim rule, March 2025 — US CTA now foreign-entity only.
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