What beneficial ownership thresholds apply in major jurisdictions?

Jurisdiction	Threshold	Register	Public access
EU (AMLD5)	≥ 25% ownership / control	National UBO registers	Originally public; restricted after CJEU C-37/20 (2022) — now legitimate-interest access in most MS
United Kingdom	> 25%	Companies House PSC register	Public
United States	≥ 25% or substantial control	FinCEN Beneficial Ownership Information (BOI) reporting	Non-public; access by law enforcement and FIs with consent
Australia	No general public UBO register (proposed under Tranche 2 reforms)	Currently extracted via ASIC company extracts + customer attestation	N/A
Singapore	≥ 25%	ACRA Register of Registrable Controllers	Non-public