Beneficial ownership transparency and family offices in 2026

Beneficial ownership transparency for family offices now depends almost entirely on where the holding structures sit. In the United States, FinCEN's final rule of 11 August 2026 permanently exempts domestic companies and US persons from Corporate Transparency Act reporting, leaving only foreign-formed entities registered to do business in a US state within scope. In the United Kingdom, the public register of people with significant control remains in force and has been strengthened by mandatory identity verification from 18 November 2025. In the European Union, the 2022 Court of Justice ruling ended unrestricted public access, and the 2024 anti-money laundering package replaces it with access for those who can show a legitimate interest, applying from 10 July 2027. Family offices with entities in all three jurisdictions face three different regimes.

United States: the Corporate Transparency Act in 2026

The CTA's reporting regime, which the 2022 rule estimated would cover about 32.6 million entities, was narrowed in two steps. Sidley summarises the sequence: nationwide injunctions in late 2024 and early 2025, a Treasury announcement on 2 March 2025 that it would suspend enforcement against US citizens and domestic companies, an interim final rule on 26 March 2025 exempting domestic reporting companies and US-person beneficial owners, and the final rule of 11 August 2026 making those exemptions permanent. Adams and Reese reports the rule took effect on 14 August 2026.

What remains, according to FinCEN's BOI page, is a reporting obligation on foreign-formed entities registered to do business in a US state or tribal jurisdiction, and only in respect of their non-US-person beneficial owners. Entities registered before 26 March 2025 had until 25 April 2025 to file; later registrants have 30 days from the effectiveness of their registration. FinCEN estimates about 28,000 such entities are in scope, of which roughly 13,000 had filed by the end of 2025. FinCEN has said it will delete previously filed information relating to US persons and domestic companies. For a US family office, the practical position is that domestic LLCs, trusts and holding companies file nothing, while a Cayman or BVI vehicle registered to do business in Delaware or Florida still files for its non-US owners.

United Kingdom: PSC register plus identity verification

The UK regime has moved the other way. Under Companies House guidance, a person with significant control is anyone who holds more than 25% of a company's shares or voting rights, can appoint or remove a majority of the board, otherwise exercises significant influence or control, or exercises such control over a trust or firm that meets one of those conditions. The register is public and includes name, month and year of birth, nationality, country of residence and the nature of control. Individuals at serious risk of violence or intimidation can apply to have their details protected.

The Economic Crime and Corporate Transparency Act 2023 added identity verification. Companies House confirmed that verification became mandatory on 18 November 2025 for new directors and PSCs, with a 12-month transition for existing ones; it expects 6 to 7 million individuals to verify by mid-November 2026, and more than 300,000 had done so voluntarily between April and the announcement. Verification is through GOV.UK One Login or an authorised corporate service provider, and acting as an unverified director will be an offence. Irwin Mitchell notes that name mismatches between register and identity documents have been the most common early problem.

European Union: from public access to legitimate interest

The CJEU's 2022 judgment in the Luxembourg Business Registers cases held that unrestricted public access to beneficial ownership data was a disproportionate interference with privacy rights. Transparency International reported that 14 member states had since built legitimate-interest access systems, that the Commission had opened infringement proceedings against 11 member states for missing the 10 July 2025 transposition deadline for the first set of AMLD6 requirements, and that from July 2026 registers must answer legitimate-interest applications within 12 working days and provide historical data. Eight of the 14 countries tested charge fees.

McCann FitzGerald sets out the Irish implementation as an example: under regulations made in 2026, applicants must show a legitimate interest in combating money laundering or terrorist financing, with journalists, civil society organisations, prospective counterparties and third-country regulated entities among the recognised categories; a granted certificate is valid for three years. The Anti-Money Laundering Regulation (EU) 2024/1624 applies directly from 10 July 2027, and the Commission must assess by 10 July 2029 whether the 25% threshold should fall to 15% for high-risk categories of entity.

What structures are caught

The 25% threshold is common to all three, but control tests catch individuals below it, and in the UK the significant influence condition is deliberately open. Family offices that restructured in 2023 and 2024 to minimise CTA filings may now wish to revisit those changes, while those with UK entities should treat the November 2026 verification deadline as fixed. The reporting the office owes its own family, as distinct from the state, is covered in reporting to the family, and the wider framework in what a governance framework contains.