Note: This article describes a Danish regulatory change specifically, affecting the CVR (Central Business Register) and its beneficial ownership records.

If you've previously done due diligence on a company, you may have looked up the business's beneficial owners directly in the CVR register yourself as part of your initial research. You can no longer do that. Since September 1, 2025, public access to information on beneficial owners has been shut down, following the EU's 6th Anti-Money Laundering Directive.

What's changed?

Previously, anyone could freely look up a business's beneficial owners in the Central Business Register (CVR). That's no longer possible. Access is now reserved for:

  • Competent authorities — including authorities with a role in combating money laundering and terrorist financing.
  • Obliged entities under the Anti-Money Laundering Act — for example banks, accountants and lawyers, who are themselves subject to a duty to investigate their clients.
  • Parties with a documented "legitimate interest" — a term still being fleshed out, but which in practice requires being able to substantiate an objective reason for access, not mere curiosity.

What does it mean for you as a buyer?

You can no longer confirm a seller's information about the business's ownership yourself simply by looking it up in the CVR register. In practice, this means that as a buyer you need to:

  • Ask the seller for the information directly as a standard part of your due diligence list, instead of expecting to verify it yourself from the outside.
  • Ask for documentation of the ownership — for example an ownership register, minutes from general meetings, or other written documentation — rather than just a verbal confirmation.
  • Consider whether you have a "legitimate interest" that could justify an application for access with the Danish Business Authority, if the seller can't or won't provide adequate documentation themselves.

What does it mean for you as a seller?

Be prepared that a buyer can no longer verify your ownership themselves from the outside — this places greater responsibility on you to proactively have the documentation ready. If you have a transparent, well-documented ownership structure ready to share as soon as a buyer dialogue becomes serious, you avoid unnecessary delays in the due diligence process, precisely because the buyer can no longer look it up themselves.

Does this apply to all types of businesses for sale?

The rules on registering beneficial owners apply to most company forms (ApS, A/S, etc.), while simpler ownership forms like a sole proprietorship typically aren't covered in the same way, since ownership here is already unambiguous and publicly known through the CVR register itself. If you're unsure what applies to your specific business, it can be clarified with the Danish Business Authority or your accountant.

Frequently asked questions

When did the closure of public access take effect?

September 1, 2025, as part of implementing the EU's 6th Anti-Money Laundering Directive into Danish law.

Can I not see a business's beneficial owners at all anymore?

Not without further ado. Access is reserved for competent authorities, obliged entities under the Anti-Money Laundering Act, and parties who can document a legitimate interest.

Should I seek out the information myself, or is it the seller's responsibility to disclose it?

It's good practice to ask the seller to disclose and document the ownership directly as part of due diligence — don't expect to be able to independently confirm it yourself via a CVR lookup anymore.

In the middle of a due diligence process and running into questions about ownership? Read the full walkthrough of due diligence when selling a business, or book a no-obligation call about the Advisory & Mediation package.

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