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Beneficial ownership thresholds and public access compared

Last checked: 20 October 2026 · Explainers

A beneficial ownership threshold is the share of ownership or votes at which a person must be recorded as a beneficial owner. FATF guidance says a threshold should not exceed 25 percent 1. Nigeria uses 5 percent 3. Kenya and Seychelles use 10 percent 2,10. Ghana uses 10 percent, or 5 percent in high-risk sectors 4. Mauritius uses 20 percent 9. The UAE uses 25 percent or more and the UK more than 25 percent 7,10. Uganda sets no percentage 6.
FATF ceiling
No more than 25 percent 1
Lowest threshold here
5 percent, Nigeria, and Ghana for high-risk sectors 3,4
No percentage test
Uganda 6
Open to the public
UK and Nigeria 3,7
Closed to the public
Kenya, UAE and Seychelles, with exceptions 2,5 10

What the FATF says about thresholds

The FATF Guidance on Beneficial Ownership of Legal Persons, published in March 2023, does not set a fixed percentage. Paragraph 37 says countries may set an ownership threshold and that it should not exceed a maximum of 25 percent 1.

Paragraph 38 says a higher money laundering or terrorist financing risk could signal the need for a lower threshold 1. Paragraph 39 says the results of a risk assessment may lead countries to apply different thresholds, for example across sectors or types of legal person 1.

  • With a 20 percent threshold, five people who each own 20 percent of the shares would all be beneficial owners (paragraph 41) 1.
  • With a 20 percent threshold, a company with as few as six shareholders could have no one above the threshold (paragraph 42) 1.
  • A shareholding well below the threshold may still give a minority shareholder control, so the threshold alone does not decide who is a beneficial owner (paragraph 45) 1.

Ownership thresholds by country

The table lists the ownership percentage in each official rule. Several of these rules add tests based on control, such as the power to appoint or remove a majority of the board 2,5 10.

CountryThresholdRule
Nigeria 3At least 5 percent of shares or voting rights 3Persons with Significant Control Regulations 2022, regulation 14 3
Zambia 8At least 5 percent of shares, defined as a substantial interest 8Companies (Amendment) Act No. 12 of 2020, section 2 8
Ghana 410 percent, or 5 percent in high-risk sectors 4Office of the Registrar of Companies FAQ 4
Kenya 2At least 10 percent of issued shares or voting rights 2Legal Notice 12 of 2020, regulation 3(2) 2
Seychelles 10Ten percent or more of controlling ownership interest 10Beneficial Ownership Regulations 2020, regulation 3(2)(a) 10
Mauritius 920 percent of shares or voting rights 9CBRD guidance note of 5 October 2026 9
United Arab Emirates 525 percent or more of capital or voting rights 5Cabinet Resolution No. 109 of 2023, Article 5(1) 5
United Kingdom 7More than 25 percent of shares or voting rights 7GOV.UK guidance on people with significant control 7
Uganda 6No percentage set 6Companies (Beneficial Owners) Regulations 2023, regulation 2 6

Lower thresholds for risk and politically exposed persons

Ghana uses a general threshold of an interest of 10 percent or more, according to its Registrar of Companies 4. For companies in high-risk sectors, the reporting threshold is five percent 4. A foreign politically exposed person with an interest of five percent or more in any company must be reported, and a domestic politically exposed person with any shares or control in any sector must be registered 4.

Zambia's 2020 amending Act counts a substantial economic benefit of at least five percent of dividends or transaction proceeds, alongside the five percent share test 8.

Tests without a percentage

Uganda's Companies (Beneficial Owners) Regulations 2023 define a beneficial owner as a natural person who has final ownership or control of a company, with no minimum shareholding 6. Kenya counts a person who can appoint or remove a majority of the board, or who has significant influence or control 2. The UAE counts a person with other control, such as the power to appoint or remove a majority of directors 5. Seychelles has a separate test for the right to appoint or remove a majority of the board 10.

Who can see the data

The FATF leaves the choice of public access to each country 1.

CountryAccessDetail
United Kingdom 7Published on the register 7Some people can apply to keep information off the public register, and home addresses must not be disclosed 7
Nigeria 3Public at no cost 3Listed fields include name, nationality, service address and nature of control, subject to limits on protected information 3
Ghana 4Some data public 4Name, month and year of birth, place of birth and ownership percentage can be made available 4
Uganda 6Any person may apply 6Application on Form 3 costs UGX 25,000 6
Kenya 2Not public 2Two exceptions, for procurement and public interest cases 2
United Arab Emirates 5Not public 5No disclosure without written approval, with exceptions for legal obligations 5
Seychelles 10Not public 10Only authorised officers of specified entities can access the database 10

Common questions

What is the FATF threshold for beneficial ownership?

The FATF does not fix one. Its March 2023 guidance says any threshold should not exceed 25 percent and may be lower for higher risks 1.

Which country has the lowest beneficial ownership threshold here?

Nigeria uses 5 percent of shares or voting rights 3. Ghana uses 5 percent in high-risk sectors 4, and Zambia counts a 5 percent substantial interest 8.

Does every country use a percentage?

No. Uganda's 2023 regulations set no minimum shareholding 6.

Is a person below the threshold ever a beneficial owner?

Yes. FATF guidance says a holding well below the threshold may still give control 1, and Kenya counts board control or significant influence 2.

Rules and fees change. Check the official site linked above before you apply or pay. Spotted an error? Email [email protected] with the official link.

Sources

  1. FATF: Guidance on Beneficial Ownership of Legal Persons, full text (March 2023)
  2. Kenya Law: The Companies (Beneficial Ownership Information) Regulations, Legal Notice 12 of 2020 (version of 19 October 2023)
  3. Corporate Affairs Commission: Persons with Significant Control Regulations, 2022 (published January 2023)
  4. Office of the Registrar of Companies, Ghana: FAQ (no date shown, read 20 October 2026)
  5. UAE Legislation: Cabinet Resolution No. (109) of 2023 Regulating the Real Beneficiary Procedures (6 November 2023)
  6. Uganda Gazette: Companies (Beneficial Owners) Regulations, 2023, Statutory Instrument 1 of 2023 (6 January 2023)
  7. GOV.UK: People with significant control (PSCs) (updated 30 July 2026)
  8. ZambiaLII: Companies (Amendment) Act No. 12 of 2020 (2 December 2020)
  9. Corporate and Business Registration Department, Mauritius: Guidance Note, Identification of Beneficial Owners under the Companies Act 2001 (5 October 2026)
  10. SeyLII: Beneficial Ownership Regulations, 2020, SI 107 of 2020 (28 August 2020)

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