It sounds like a detail for lawyers, but it is not: with the new EU anti-money laundering package, the threshold for identifying the beneficial owner changes from “more than 25%” to “25% or more”. A small change in wording that brings thousands of corporate positions within the scope of due diligence. Anyone who today holds exactly 25% of a company is not a beneficial owner; once Regulation (EU) 2024/1624 (AMLR) applies from July 10, 2027, they will be, and will have to be identified and verified as such.
Beneficial ownership at 25%: what the new AML package says
The EU anti-money laundering package consists of three acts: the AMLR Regulation (EU) 2024/1624, the AMLD6 Directive (EU) 2024/1640 and Regulation (EU) 2024/1620 establishing the European authority AMLA. The substantive rules on beneficial ownership, including the thresholds, are contained in the AMLR, which will be directly applicable in all Member States without the need for transposition. AMLD6, on the other hand, mainly addresses beneficial ownership registers, access to information and the powers of national authorities.
The underlying logic remains the familiar one: the beneficial owner is the natural person who, directly or indirectly, owns or controls the legal entity, through a shareholding in the capital, voting rights, other ownership interests or other forms of control. What changes, however, is the entry threshold, and the way indirect corporate chains must be reconstructed and documented.
Not just 25%: lower thresholds for high-risk sectors
The AMLR also provides for the European Commission to assess the sectors and categories of legal entities exposed to a higher risk of money laundering and terrorist financing and, through delegated acts, to set thresholds below 25% for them. The minimum limit indicated is 15%, unless the risk justifies a threshold that is in any case below 25%. The Commission’s assessment is expected by July 10, 2029.
For obliged entities this means something concrete: the threshold is no longer a fixed number to hard-code into processes once and for all, but a parameter that varies by sector. Those who built controls and systems around “more than 25%” will need to be able to reconfigure them without rewriting the entire architecture.
The Italian framework: the beneficial ownership register and access
In Italy, Legislative Decree 231/2007 continues to govern the matter until the AMLR applies. On the registers front, Legislative Decree No. 210 of December 31, 2025, in force since January 9, 2026, implemented the AMLD6 provisions on access to beneficial ownership information, tightening the conditions for access by private parties, which must be based on a relevant and specific legal interest and on concrete, documented evidence.
The operational consequence is less intuitive than it seems: if access to registers becomes more selective, the register can no longer be the starting point and the end point of due diligence. You need an independent ability to reconstruct the chain of control from corporate sources, company register extracts, deeds and shareholdings, including foreign and multi-level ones.
What changes for your company
- Review the threshold in your systems: every rule, filter or field that currently applies “> 25%” must be changed to “≥ 25%” and made configurable by sector.
- Re-screen your existing portfolio: holdings of exactly 25%, currently out of scope, will become beneficial owners to be identified and verified.
- Strengthen your analysis of indirect chains: multi-level shareholdings and foreign vehicles require calculating effective ownership along the entire chain, not just at the first level.
- Document the method: with AMLA supervision on the way, what matters is being able to show how you arrived at the beneficial owner, not just the final name.
- Plan ahead: July 10, 2027 is not a distant deadline for those who need to remap records and review past files.
How AegisX helps you
Manually reconstructing a chain of control across multiple levels and jurisdictions is slow, costly and hard to document. With Lensis, the analysis of corporate structures and the identification of the beneficial owner are automated: the chain is reconstructed, the effective percentage calculated and the result made traceable and verifiable. The result then feeds into the sanctions, PEP and adverse media screening of Monitus, so customer due diligence becomes a single process instead of a series of disconnected steps.
Want to find out how many positions in your portfolio change status with the new threshold? Talk to the AegisX team and turn compliance into a strategic advantage.
This article is for informational purposes only and does not constitute legal or compliance advice.
