AML: Transparency International's survey on beneficial ownership registers

On 25 September 2025, the European Commission announced the launch of infringement proceedings against 11 Member States, including Italy, for failing to "fully notify" the measures taken to transpose the 6th Anti-Money Laundering Directive (the "6th Directive") by the deadline of 10 July 2025. In particular, the proceedings concern the first set of provisions on access to beneficial ownership information, including access based on legitimate interest.

The Sixth Directive is an important piece of European Union legislation which, following the Court of Justice ruling that ended general public access to beneficial ownership registers, established access based on the principle of legitimate interest. In particular, for journalists, civil society and academia engaged in work related to anti-money laundering or predicate offences, the Sixth Directive requires a legitimate interest in order to access the registers, rather than access on a case-by-case basis. Member States will have until July 2026 to further transpose these operational provisions.

To take stock of the situation, Transparency International (hereinafter also 'Transparency') tested the possibility of accessing beneficial ownership registers for persons with a legitimate interest in 14 EU countries that have already implemented this type of regime. The results painted an 'alarming' picture because, les...