CySEC Circular C810 flags the EU formats for beneficial ownership filings from July 2027

With Circular C810, dated 27 October 2026 and issued further to Circular C738, CySEC informs its regulated entities that Commission Implementing Regulation (EU) 2026/2354 of 16 October 2026 on formats for submitting beneficial ownership information was published in the Official Journal of the EU on 22 October 2026.

According to CySEC, the Regulation lays down common formats for submitting beneficial ownership information to central registers across the EU, so that data quality, consistency and interoperability among the registers improve. It applies from 10 July 2027 and is directly applicable in all Member States. CySEC encourages regulated entities to take its provisions into consideration and sets no deadline or Cyprus-specific requirement of its own.

The Regulation is adopted under Article 10(6) of Directive (EU) 2024/1640. For each beneficial owner it fixes how personal data are entered: all first names and surnames in full, dates as yyyy-mm-dd, countries from ISO 3166-1 alpha-3, nationality with multiple choices and a stateless option, and addresses with street or house name, city, postal code and country as obligatory fields.

The nature and extent of the interest is chosen from set options. Ownership is direct or indirect and given as a percentage with two decimal points. Control can run through ownership, voting rights, appointment or veto rights, profit distribution, agreements, family relationships, acting in concert or nominee arrangements. Where no beneficial owner can be identified, the filer gives the reason from a fixed list, for example dispersed ownership, or that none could be determined after exhausting the means in Articles 51 to 57 of the AMLR. Collective investment undertakings report holdings of units, the ability to define or influence the investment policy and control through other means instead.

For trusts and similar arrangements the roles are settlor, trustee, beneficiary, object of a power, default taker and protector. The trust deed and its addenda are uploaded, and the value of the assets is given in bands from under EUR 1 000 to over EUR 50 000 000. Nominee shareholders, nominee directors and their nominators are reported too, with whether a formal nominee contract or an informal agreement exists.

Article 5 sets a checklist. A central register may accept a submission only when at least the listed personal data, the data on the beneficial interest and the basic data on the legal entity or arrangement are present. Where the ownership and control structure contains more than one legal entity or legal arrangement, a description of that structure is required as well. It is either an organisational chart that shows every entity and arrangement that owns or controls the filer, the nature and extent of ownership or control, whether it is direct or indirect, and the percentages, or proof that ownership is dispersed.

Data that already sits in another register is reused, or requested in the format already established there. According to the recitals, registrations made before 10 July 2027 should not be affected by the formats immediately, but Member States could reasonably require updates to existing entries to follow them. For background, see our study note on beneficial ownership registers.