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Beneficial Ownership: Corporate Entities
The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) (Amendment) Regulations 2026 (PDF 250KB) have been published and amend the 2019 Beneficial Ownership of Corporate Entities Regulations to implement aspects of the Sixth Anti-Money Laundering Directive. The amendments largely reflect the changes introduced in July to the Beneficial Ownership of Trusts Regulations.
The principal changes are:
- Expanded unrestricted access to the Central Register: Unrestricted access rights have been extended to additional Irish and EU authorities, including an assistant registrar to the Registrar of Beneficial Ownership of Trusts, officers of the Minister for Foreign Affairs and Trade and of the Minister for Enterprise, Tourism and Employment, the CBI, AMLA, EPPO, OLAF, Europol and Eurojust.
- New legitimate-interest access regime: Individuals may apply for a certificate granting access to certain beneficial ownership information (including, for certain categories of individual, access to historical beneficial ownership information) where they can demonstrate a legitimate interest in combating money laundering and terrorist financing. Certificates are valid for three years (unless revoked). Certain categories of individual will be deemed to have a legitimate interest.
- Statutory response timeframes: From 10 November 2026, the Registrar must respond to a submission for a legitimate-interest certificate within 12 working days, subject to limited extensions e.g. in periods of high demand. Subsequent requests to inspect information by a person who has been issued with a certificate must be responded to within 7 working days.
- Enhanced protections for vulnerable beneficial owners: In addition to minors, further safeguards now apply to persons lacking capacity and individuals at risk of harm if their information is disclosed.
- New appeal right: Applicants refused a certificate, or whose certificate is revoked, may appeal to the District Court within 10 working days.
- Fee restrictions: Fees may only be charged to cover the costs of maintaining information quality and facilitating access to the Register.
Beneficial Ownership: Limited Partnerships
The Government has published its National Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing, Strategy 2026. In addition to the recent changes made to the legislation governing the beneficial ownership of corporate entities and trusts, the Department of Finance intends to introduce measures requiring the mandatory disclosure of the ultimate beneficial owners and controllers of all limited partnerships.
The Department of Enterprise, Tourism and Employment recently consulted on targeted reforms to Ireland’s limited partnership framework. These reforms are expected to be progressed through the Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill 2024. The general scheme of the Bill provides for the establishment of a register of beneficial ownership of partners of a limited partnership incorporated or administered outside the EEA. It is anticipated that the Bill will be published later in 2026.
We will continue to monitor legislative developments in this area and provide updates as the proposed reforms progress.
CASE LAW: Rectification of Register of Members
In Palmer v P1 Pit Stop Ltd [2026] EWHC 1924 (Ch), the High Court of England and Wales held that section 125 of the UK Companies Act 2006 (the equivalent of section 173 of the Companies Act 2014) empowers the court to create a register of members where a company has failed to maintain one. The court found that the statutory power to rectify omissions in a register extends to the creation of a register where none exists and the order had retrospective effect, deeming the members to have been registered from the date they ought to have been entered.
DEPARTMENT OF FINANCE PUBLICATIONS
The Department of Finance has published its Annual Report 2025 (PDF 1,152 KB) setting out the range of activities and achievements of the Department during 2025, and has launched the new Ireland for Finance Strategy 2026-2030.
The Strategy responds to an increasingly complex and competitive global regulatory environment and sets out four core ambitions, supported by 31 actions, to reinforce Ireland’s position as a trusted international financial services centre, support EU growth and expertise, leverage digital transformation and strengthen links with domestic businesses and citizens. Key measures include modernisation of the ICAV, Companies Act and limited partnership regimes, a more coordinated approach to transposing EU financial services legislation through a multi-annual legislative plan and new Policy Delivery Forum, the Central Bank’s Simplification Roadmap and further tax policy reviews, including in relation to Section 110, R&D tax credits and innovation incentives, to support Ireland’s competitiveness as a location for inward investment.
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