The Problem BORIS Was Built to Solve
Every compliance officer running KYB checks across Europe has hit the same wall. You need to verify the ultimate beneficial owner of a company in Germany. Then another in France. Then one in Latvia.
Three countries. Three different registers. Three different access rules, languages, and data formats.
This is the fragmentation problem the European Commission set out to fix with BORIS.
BORIS stands for Beneficial Ownership Registers Interconnection System. It’s the EU’s attempt to link all national UBO (Ultimate Beneficial Owner) registers into a single, searchable system hosted on the European e-Justice Portal.
The idea is simple: one search, access to beneficial ownership data across all EU Member States, plus Iceland, Liechtenstein, and Norway.
The reality? It’s more complicated.
How BORIS Works
BORIS is a decentralised system. It doesn’t store beneficial ownership data in one central database. Instead, it connects to the national registers that each EU Member State is required to maintain under anti-money laundering directives.
Here’s the process:
01 — SEARCH | 02 — ROUTE | 03 — RETRIEVE | 04 — DELIVER |
|---|---|---|---|
User queries by company name or registration number on the e-Justice Portal. | BORIS routes the request to the relevant national register via the European Central Platform. | The national register returns a standardised BO Record with beneficial ownership data. | User downloads the record as a PDF extract. One company at a time. Fees vary by country. |
The system was established under EU Implementing Regulation 2021/369, which set the technical specifications for how national registers connect to the central platform.
What Data Does a BO Record Include?
Every national register connected to BORIS must provide a minimum set of fields for each beneficial owner:
Full Name | Date of Birth | Residence | Nationality | Beneficial Interest |
|---|---|---|---|---|
Name and surname of the beneficial owner | Month and year of birth only | Country where the UBO resides | Country of nationality | Nature and extent of ownership or control |
Individual Member States can expand beyond this minimum. Austria and Sweden, for example, provide more complete datasets than most. But the baseline is intentionally narrow, reflecting privacy concerns that have shaped the entire system.
The Legal Timeline Behind BORIS
BORIS didn’t appear overnight. It’s the product of a decade of evolving EU anti-money laundering legislation:
Year | Directive | Event | Impact |
|---|---|---|---|
2015 | AMLD4 | Registers Mandated | EU requires all Member States to create central UBO registers. Access limited to authorities. |
2018 | AMLD5 | Public Access Granted | Registers opened to public. BORIS interconnection mandated. |
2021 | Reg 2021/369 | BORIS Goes Live | Technical specifications enacted. First 3 countries connected. |
2022 | CJEU Ruling | Public Access Reversed | Court strikes down open access as disproportionate interference with privacy rights. |
2024 | 6AMLD | Legitimate Interest Model | New access framework adopted. Harmonised UBO definition enacted. |
2026 | Deadline | Full Transposition Due | Member States must comply by July. Historical data and 12-day SLA required by November. |
2027 | Full Effect | All Rules In Force | Complete 6AMLD compliance required. EU AML Regulation fully active. |
AMLD4 (2015): The Foundation
The 4th Anti-Money Laundering Directive required all EU Member States to create central registers of beneficial ownership information. This was the first time the EU mandated that companies identify and register their UBOs. Access was limited to competent authorities and obliged entities conducting due diligence.
AMLD5 (2018): Public Access
The 5th Directive went further. It required Member States to make beneficial ownership registers publicly accessible. Anyone could look up who owned a European company. AMLD5 also mandated the interconnection of these national registers — the legal origin of BORIS itself.
For compliance teams, journalists, and civil society, this was a breakthrough. Ownership transparency across the EU was finally becoming a practical reality.
The 2022 CJEU Ruling: Public Access Reversed
Then in November 2022, the Court of Justice of the European Union issued a landmark ruling. In the joined cases WM and Sovim SA versus Luxembourg Business Registers, the Court struck down the blanket public access requirement.
The Court’s reasoning: giving any member of the general public unrestricted access to beneficial ownership data was not proportionate. It represented a serious interference with the right to privacy and data protection under the EU Charter of Fundamental Rights.
The impact was immediate. Several countries closed or restricted their registers. Czechia, for example, fully shut its public register in December 2025. Others left their systems open while scrambling to define new access rules.
6AMLD (2024): Legitimate Interest Access
The EU’s response came in May 2024 with the adoption of the 6th Anti-Money Laundering Directive. Rather than restoring full public access, 6AMLD introduced a “legitimate interest” framework.
Under this model, access to UBO registers is available to:
Competent authorities and Financial Intelligence Units (unrestricted access)
Obliged entities conducting customer due diligence (banks, financial institutions)
Journalists, civil society, and academics working on AML-related topics (presumed legitimate interest)
Third-country obliged entities subject to AML requirements (case-by-case)
Member States have until July 2026 to transpose the operational rules. From November 2026, registers must respond to legitimate interest requests within 12 working days.