Financial Transparency Coalition

The issue of public access to shareholder registries is currently under consideration in the most recent case before the European Court of Justice (ECJ) concerningthe transparency of shareholders in publicly accessible limited companies in Latvia (Case C-798/24), which was referred to the court by the Latvian Constitutional Court (Satversmes tiesa).

As the Financial Transparency Coalition (FTC), we believe that such information should remain public and that the Latvian case provides an important test for transparency. Public access can help prevent and hold owners accountable for potential environmental and human rights harms, tax abuses enabled by corporate structures, as well as risks related tocorruption and money laundering.

The issue of publicly accessible shareholder registries extends beyond Latvia and affects most countries in the broader Nordic-Baltic region. In Estonia, the shareholder registries of publicly listed companies are also open to the public, with all minority shareholders visible down to the last share. The same applies in Lithuania, Finland, and Norway. Sweden, however, applies a threshold of 500 shares.  Ukraine and Slovenia also have a portal for shareholder data disclosure.  The case now at ECJ will impact all EU countries, and possible future candidate states.

The case is similar to a 2022 case at the European Court of Justice (cases C-37/20 and C-601/20), where a Luxembourgish property developer challenged open public registries of beneficial owners for unlisted companies. The developer argued that such registries were a disproportionate infringement of privacy in relation to the goal of combating money laundering and terrorist financing, which was the purpose of the EU’s 5th Anti-Money Laundering Directive (AMLD5) that made these registries publicly accessible. Following the ECJ ruling, the AMLD6 revised access for legitimate interest entities, such as journalists and civil society organizations, but introduced barriers and restrictions.

The debate centres on whether the disclosure of public shareholder information is a disproportionate infringement on an individual’s right to privacy. The argument concerns the disclosure of personal data, which under the EU’s General Dat Protection Rule (GDPR) is typically made public only when necessary, rather than through blanket disclosure. However, shareholders exercise control over powerful companies and financially benefit from corporate actions, while individuals in political or other decision-making roles can personally gain from public contracts or other decisions favoring companies.

Most other European countries require reporting only for major shareholders, such as when shareholders exceed thresholds of 5%, 10%, or 20% of shares, or when listing the 20 largest shareholders. For very large companies, this system can still conceal significant shareholdings, often amounting to multiple millions, as these thresholds for public disclosure may not be met. However, in some countries, the entire list of shareholders of publicly traded companies is publicly accessible (e.g., Estonia). This level of transparency is now at risk of being restricted.

In Latvia, the shareholder registry is one of the documents available through Latvia’s Register of Enterprises (Uzņēmumu reģistrs, UR) at ur.gov.lv. You can request access by creating a username and logging in, with a fee ranging from 5 to 25 EUR. The registry is accessible online to anyone; however, it is relatively easy to conduct trades through a foreign entity or a holding company listed as the shareholder.

In Estonia, you can access public shareholder data in two ways. First, the Estonian E-Business Registry provides a public portal where you can view any shareholder holding more than 10% of voting rights—for example, for the Tallink cruiseliner group—unless they are indirect or institutional shareholders. Second, the legally enforceable registry is maintained by the Estonian Central Register, operated locally by Nasdaq CSD. You can also access the full list of all shareholders of the Tallink Group by selecting the pull-down menu “SHS TALLINK GROUP ORD,” which displays all holders down to those owning a single share, along with shareholders of other companies traded on Nasdaq Estonia.

In Lithuania, the central business registry that maintains shareholder registries requires an authenticated request, which necessitates access to authentication software. Therefore, it is not possible to quickly obtain a list of shareholders. In Norway, the shareholder registry can be accessed through various portals, such as the Euronext Oslo Public Shareholder Portal, where you can sign up and directly access data on listed companies. Using this service requires verification via a Norwegian, Danish, or Swedish ID method, or alternatively, you can verify your identity by emailing them directly.

In Finland, shareholder registries are also public, but accessing them requires some effort. To obtain a shareholder registry from Euroclear Finland, you can either view the public register for free on-site or submit a paid official request for a formal report. Additionally, many shares are so-called “nominee registered,” meaning the broker or foreign holding company is listed as the shareholder instead of the beneficial owner. The practice of nominee registration has sparked public debate in Finland, with proposals to abolish it and to allow the transfer of shareholder registries abroad, enabling the use of less stringent public shareholder registry regulations in most other European countries.  Finnwatch, a Finnish NGO, campaigned in 2015 against the proposed expansion of the nominee registration of shares.  A new law in 2017 also banned unlisted Finnish companies from owning nominee registered shares in public companies to bypass the public shareholder registry, and legislation already banns Finnish residents from holding nominee registered shares (but this is hard to monitor).

The public interest uses of shareholder registries in countries where they exist are quite broad and extend well beyond combating money laundering and terrorist financing. Their primary purpose is to protect democracy, prevent harmful business practices, and uphold accountability more generally. For example, shareholdings of individuals holding political positions are often monitored through these registries, as are those who may engage in insider trading or cartel activities. The use of nominee shareholders, private equity funds, and other private investment vehicles already undermines public shareholder transparency; however, eliminating these registries would invalidate the case for public access to this information.

If the case is lost, legitimate interest access restrictions will also be imposed on these registries, or they may even be closed to public access altogether. Instead, we should expand the use of public shareholder registries across Europe and worldwide, especially in times when political office is increasingly abused for private gain and corporate malpractices—ranging from human rights and environmental violations to tax abuses—are far too common. Knowing who owns what is a fundamental part of keeping business free from corruption and accountable to wider society.