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Beneficial owner: verification requirements in 2026

Identify the beneficial owner is no longer just a simple administrative formality. For teams responsible for compliance and KYC/KYB procedures, this verification determines whether a business relationship can be established, the quality of the customer file, the level of due diligence applied, and the ability to justify a decision during an audit.

AP Solutions IO helps you secure this step with a RegTech that is traceable, auditable, and evidence-based. You can view our KYC/KYB solutions or request a demo to evaluate your current system.

What is a beneficial owner (UBO)?

The beneficial owner, or UBO, an acronym forUltimate Beneficial Owner, refers to the natural person who actually owns or controls a company, either directly or through a chain of ownership.

For a regulated entity, the issue is operational: knowing who is behind a legal entity before establishing a relationship, authorizing a transaction, approving a payment, or working with a partner.

The analysis does not stop at the name of the client company. You must go back to the individuals who hold more than 25% of the equity or voting rights, or who exercise controlling influence by other means. When this search does not identify a natural person, the legal representative may be designated in accordance with applicable rules. This definition and these thresholds are likely to be amended shortly with the new AMLR.

This audit strengthens your AML-CFT complianceand your and , and your ability to demonstrate appropriate due diligence. It also ties into KYC, KYS (Know Your Supplier), to screening for international sanctions and the identification of politically exposed persons.

Identifying the beneficial owner: thresholds, chain of ownership, and registry

The identification process begins with a thorough review of the ownership structure. A company may be owned by another company, which in turn may be controlled by a holding company, a fund, a foreign trust, or multiple individuals located in different jurisdictions.

Compliance work therefore involves reconstructing the chain of custody back to the individuals concerned.

A growth chart featuring stacks of gold coins and a glowing upward-pointing arrow, illustrating the identification and financial transparency associated with the beneficial owner.

To ensure the reliability of the analysis, the verification of the beneficiary can can be based on several specific checks: direct and indirect ownership of capital, voting rights, control agreements, and cross-referencing with the Beneficial Owners Registry and supporting documents collected.

It must also enable the identification of inconsistencies between statements, corporate documents, and external databases, and then retain evidence that can be used for auditing, internal control, and regulatory purposes.

The Beneficial Owners Registry provides a useful starting point, but it does not replace your own analysis. Reported data may be incomplete, outdated, or insufficiently documented.

Your responsibility is to verify, validate, and track the decision. An approach known as "Glass Box", based on decision transparency, comes into its own here: you need to understand why an alert appears, what data it is based on, and how the decision was validated.

Audit requirements in 2026 and the connection to KYB

In 2026, the requirements for verification obligations of the beneficiary will will be subject to stricter regulatory requirements. Entities subject to these requirements must have a better understanding of their business clients, partners, counterparties, and ultimate beneficiaries.

The KYB, or Know Your Business, thus becomes an operational pillar of compliance.

This verification is conducted at the outset of the relationship and must then be updated based on the level of risk. A change in capital structure, a change in management, the opening of a new location, an unusual transaction, or a sanctions-related alert may warrant a review.

The file must demonstrate that your organization has identified the relevant individuals, exercised appropriate due diligence, and retained the necessary supporting documentation.

The link to due diligence and KYC is clear. A supplier, distributor, intermediary, or partner can expose your organization to risks of money laundering, terrorist financing, sanctions, corruption, or reputational damage.

Link the verification of the beneficial owner to your due diligence and KYS processes prevents gaps between procurement, compliance, legal, and finance.

AP Solutions IO views this verification as a chain of evidence. The result must be available, explainable, documented, time-stamped, and reusable during an internal review, an ACPR audit,ACPR or DGCCRF or a request from Tracfin.

Common challenges faced by compliance teams

Challenges rarely arise in the simplest cases. They tend to surface when the structure is fluid, international, fragmented, or poorly documented.

A foreign holding company, a complex chain of ownership, interrelated minority shareholders, or inconsistent registry data can slow down the analysis and lead to a surge in internal requests.

Compliance teams must also deal with false positives. A name match with a sanctioned individual, outdated data on an executive, a shared address, or a recent change in beneficiary can trigger an alert that is difficult to analyze and document.

The risk isn't limited to operational processing. It also affects your ability to explain a decision, justify establishing a relationship, or prove that enhanced due diligence was applied at the right time.

Traditional methods reach their limits as volumes increase. Scattered files, manual searches, untraceable screenshots, and email confirmations make it difficult to demonstrate compliance.

Regulatory oversight is becoming more burdensome, even as compliance departments are required to reduce processing times and ensure greater certainty in their decisions.

Automate verification with AP Scan and AP Scoring

Automation provides an operational solution when it remains manageable, configurable, and auditable. AP Solutions IO favors an augmented intelligence approach based on the Glass Box model: technology accelerates analysis without obscuring the decision-making process.

You can view the data used, the criteria applied, the signals detected, and the decision-making process.

With AP Scan, you can enhance the detection and identification of individuals, companies, Beneficial Owners, PEPs, sanctions, and high-risk profiles. The solution integrates with your KYC/KYB workflows SaaS and via API, with an open, multilingual architecture suitable for both large enterprises and ME.

With AP Scoring, you can structure your risk scoring based on configurable criteria. Our models are based on more than 90 criteria and help reduce 98% of false positives, depending on the configuration and use case.

This performance isn’t based on a black box. It relies on understandable rules, adjustable settings, and traceability that your teams can use.

Continued AP Solutions IO also includes AP Monitoring for continuous monitoring and AP Filter for screening of sanctions. This provides you with a common foundation for linking KYC, KYB, KYT, transaction monitoring, enhanced due diligence, and periodic review.

AP Solutions IO is now connected to the French RBE (INPI) and to various international registries that allow access via API, such as the UK. TheThe AMLA has issued a formal notice in 2025 to all European Union member states to provide entities subject to AML-CFT its partners with access to such national registries as soon as possible.

A meeting of professionals in a conference room analyzing a network of interconnected companies centered around a key figure, illustrating AP Solutions IO’s expertise in demonstrable compliance.

A French RegTech solution designed for demonstrable compliance

AP Solutions IO is a French RegTech based in Paris, at 9 rue des Colonnes. Our solutions were designed in collaboration with recognized experts in AML-CFT compliance, who bring more than 15 years of experience in sanctions, KYC, KYB and transaction monitoring.

Hosting in France meets requirements for sovereignty, data protection, and compliance GDPR.

Our approach toexplainable AI also meets the requirements of the European regulation on artificial intelligence, often referred to asAI Act. Organizations must be able to understand, document, and monitor the systems that influence their compliance decisions.

Our regular updates, published every four months, our integrated regulatory monitoring, and our recognition RegTech100 2025, Leading 50™ FCC, Wavestone's Top Pick, Platform58 confirm the positioning ofAP Solutions IO.

We offer a robust, up-to-date, and accessible solution for organizations with high standards, bridging the gap between legacy platforms that lack flexibility and newer solutions whose operational maturity is still being established.

FAQ on Beneficial Owners

What is a UBO?

A UBO, or Ultimate Beneficial Owner, corresponds to the beneficial owner of a company. This is the individual who actually owns or controls the entity, either directly or indirectly.

What threshold of possession triggers identification?

The threshold generally applied applies to individuals who hold more than 25% of the capital or voting rights. The analysis must also take into account control exercised by other means. These rules are likely to change with the introduction of theAMLA and theAMLR.

What sources should be used to identify the beneficial owner?

You can rely on the Beneficial Owners Registry, corporate documents, supporting documents provided by the client, and partner data sources.

Reliability depends on cross-checking information, never on a single piece of data.

How can we make the verification process more reliable?

The reliability of the process is based on a consistent methodology: data collection, verification, reconciliation, screening, risk assessment, validation, and retention of evidence.

With AP Scan and AP Scoring, AP Solutions IO helps you scale this pipeline while maintaining a Glass Box, explainable, and auditable approach.

Verify the beneficial owner using a reliable chain of evidence

The verification of the beneficiary effectively affects your compliance, your risk exposure, and your ability to meet regulatory requirements. In 2026, the challenge is to move beyond ad hoc searches to implement a sustainable, that is sustainable, documented, and manageable.

AP Solutions IO supports you with a SaaS connected via API, hosted in France, designed for AML-CFT, KYC, KYB, KYT, sanctions screening and the reduction of false positives.

You can view our KYC/KYB solutionsand enhance your approach with AP Scan , and structure your scoring with AP Scoring. To assess integration into your existing system, request a demo