Ireland has introduced two parallel sets of regulations implementing new rules under the Sixth Anti-Money Laundering Directive (“AMLD6″): the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) (Amendment) Regulations 2026 (S.I. No. 335 of 2026) and the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) (Amendment) Regulations 2026 (S.I. No. 406 of 2026) (together, the “Regulations“). In practice, Irish companies (including special purpose vehicles and other corporate group entities) and trustees of Irish trusts should expect their beneficial ownership information to be accessed more as the application process has been simplified for certain categories of applicant.
Between them, the Regulations govern third-party access to (i) the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies; and (ii) the Central Register of Beneficial Ownership of Trusts (each a “Register”). The Registers were subject to general public access until 2023, when Ireland introduced regulations which limited access to those with a legitimate interest in the prevention and combating of money laundering and terrorist financing (a “legitimate interest”). This change was necessitated by a Court of Justice of the European Union ruling in 2022 which determined that general public access was invalid on privacy grounds. Under the Regulations, access to each Register remains limited to persons with a “legitimate interest”. What the Regulations have now introduced is a detailed statutory framework around that test.
Each of the Regulations introduces a new prescribed list of persons who are deemed to have a legitimate interest for the purposes of making a submission. This list includes journalists, civil society organisations, and persons likely to enter into a transaction with the relevant entity (where such persons are acting for purposes connected with the prevention of money laundering or terrorist financing). They must still apply to the relevant registrar, but no longer need to establish their interest case by case or show a link to a specific entity or trust. The registrar must decide applications within 12 working days. Successful applicants receive a three-year access certificate.
Filed information, including historical information for up to five years, will be more readily accessible and may be revisited throughout the life of a certificate. The mandatory 12-working-day decision period applies from 10 November 2026. Ahead of that date, entities and trustees should ensure that their internal beneficial ownership registers and their filings on the relevant Register are accurate and up to date. This means reviewing previous filings, reconciling internal records with central register filings, and ensuring filings are kept up to date as ownership changes.
The Regulations amend the regimes for companies and trusts only. ICAVs, unit trusts, common contractual funds and investment limited partnerships remain subject to the separate Central Bank of Ireland Beneficial Ownership Register for Certain Financial Vehicles. Corresponding changes to that regime can be expected to follow in due course.
