Who is a UBO? Ownership charts that pass onboarding the first time
The 25 % rule, indirect ownership, control without shares — and how to draw a chart a reviewer can verify in minutes.
An ultimate beneficial owner (UBO) is the natural person who ultimately owns or controls a company. The EU threshold is more than 25 % of shares or voting rights, held directly or through other entities.
Indirect ownership is multiplied
If Anna owns 60 % of Holding B, and Holding B owns 40 % of your company, Anna indirectly owns 24 % — just under the threshold. Add a 2 % direct stake and she crosses it.
Control without ownership
A person can be a UBO through other means: the right to appoint directors, a shareholders' agreement, or a trust arrangement. If nobody qualifies, the senior managing official is recorded instead.
What a good chart looks like
One page. Boxes for each entity with name, country and registration number. Arrows with percentages. Natural persons at the bottom, highlighted. Date and signature of a director.
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