Update on public access to Ultimate Beneficial Owners (UBOs) register

In light of the recent European Court of Justice judgement, public access to the UBOs Register for companies, as provided for in Directive 2018/843, was ruled invalid.

Following the above judgement, EU Member states have suspended access to the UBOs Register for companies by the public at large.



As provided for by the Department of Registrar of Companies and Intellectual Property (the “RoC”) in its announcement of 28/11/2022, obliged entities, as defined in the Cypriot AML Law, which among others include lawyers, independent legal consultants, administrative service providers providing fiduciary services (nominee directors, nominee shareholders etc) banks, auditors, tax consultants etc., will be able to request and receive beneficial ownership information in the context of performing their customer due diligence obligation subject to submitting a statement called, “Solemn Declaration”.

On 03/01/2023, the RoC has issued a follow up announcement, publishing a template form of the Solemn Declaration.

As per this form, the physical or legal persons requesting access to the UBOs Register, filing the Solemn Declaration, will need to declare that:

  1. they are an obliged entity according to Article 2A of the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 (188(I)/2007) and
  2. the reason for requesting the information is within the context of performing customer due diligence and
  3. they have knowledge that any false and/or misleading statement would be subject to penalties, being a criminal offence under the penalty of perjury in accordance with the Laws of the Republic of Cyprus.



The UBOs Register for companies is not accessible to the public at large. Apart from the relevant authorities, as specified in the Cypriot AML Law, obliged entities may also gain access to it, provided they meet the conditions set out by the RoC in the Solemn Declaration.



This publication has been prepared as a general guide and for information purposes only. It is not a substitution for professional advice. One must not rely on it without receiving independent advice based on the particular facts of his/her own case.  No responsibility can be accepted by the authors or the publishers for any loss occasioned by acting or refraining from acting on the basis of this publication.



Yiolanda Rotsides

Senior Associate Lawyer – Legal Department



We are a Law Firm with offices in Cyprus consisting of more than 50 lawyers, accountants and other professionals, consulting international and local clients.

The Firm and its predecessors offer to their clients legal and advisory services since 1983. The Firm gradually evolved over the years, from one traditional law Firm into an innovative pioneering Law Firm that combines exceptional expertise in corporate law, trusts, taxation, VAT, accounting, litigation, financial services, labour law, migration and technology.

Since its establishment, the focus of the Firm has been largely oriented towards corporate businesses and always compatible with the latest global developments and innovations.

Drawing from the team of our experienced professionals, we provide to the clients' businesses our full legal, tax and accounting support on a daily basis as well as tailored solutions to today's global economic and legal challenges. Our Firm is constantly harmonizing and adapting to technological developments by providing a corresponding support to its customers.

It is our policy to anticipate and prevent any issues that may arise and impact our clients' businesses and offer effective advice, timely and proactive solutions.

We participate in the operations of our customers and have as our vision and pride to become part of their story having as flag, the motto "...Being part of their story is our pride..."



Kinanis LLC
Limited Liability Law Firm
Egypt 12, 1097 – Nicosia
Tel: 22 558 888 – Fax: 22 662 500
E-mail: KinanisLLC@kinanis.com
Website: www.kinanis.com