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UBO thresholds by country, compared

A comparison of beneficial-ownership disclosure thresholds across the EU, UK, US, Switzerland, UAE, Singapore, India and more.

The FLIORE Compliance Desk
Family-office compliance research
7 min read
Updated 2026-07-01
Key takeaways
  • 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

Which threshold governs a multi-country structure?
Each entity is assessed against its own jurisdiction; document where they differ.
Did the US abolish UBO reporting?
No — it narrowed it to foreign entities only.
Sources
  • EU AMLR 2024/1624 — 25% EU threshold from 2027.
  • FinCEN interim rule, March 2025 — US CTA now foreign-entity only.

Related guides

The 25% UBO threshold, explainedThe EU AML Regulation: what changes in 2027Switzerland's transparency register (LETA)

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UBO thresholds by country, compared · FLIORE