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UBO & KYC

The 25% UBO threshold, explained

Where the 25% beneficial-ownership threshold comes from, when it drops to 15% or 10%, and how to apply it across ownership chains.

The FLIORE Compliance Desk
Family-office compliance research
6 min read
Updated 2026-07-01
Key takeaways
  • 25% is the default disclosure threshold in the EU and most FATF-aligned regimes.
  • High-risk sectors can trigger a 15% threshold in the EU; some countries use 10% or 5%.
  • Indirect ownership is calculated by multiplying through the chain.

The default

The 25% figure is the threshold at which an owner is presumed significant enough to disclose. Under the EU AML Regulation it applies uniformly across member states from 10 July 2027, replacing the older directive patchwork.

When it drops

For certain high-risk sectors, EU member states may impose a lower threshold — down to 15% — with Commission approval. Outside the EU the range is wider: India applies 10%, South Africa 5%. A cross-border family is therefore assessed against several thresholds at once.

Indirect ownership

When ownership runs through intermediate entities, you multiply the percentages along the chain. A person owning 50% of a company that owns 50% of the target holds 25% indirectly — exactly on the threshold. Getting this arithmetic right across complex structures is where mistakes happen.

FAQ

Does 24.9% mean no disclosure?
On ownership alone, often yes — but control tests can still make that person a UBO.
Which threshold applies to a cross-border structure?
Each entity is assessed against the rules of its own jurisdiction; the strictest applicable rule usually governs.
Sources
  • EU AML Regulation 2024/1624 — Single 25% threshold from July 2027.
  • 6th AML Directive — Standardised UBO definitions across the EU.

Related guides

What is an ultimate beneficial owner (UBO)?The EU AML Regulation: what changes in 2027UBO thresholds by country, compared

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The 25% UBO threshold, explained · FLIORE