How to verify who really controls a company: the beneficial owner guide

In short: the legal representative of a company — the person who signs the contracts — and the beneficial owner — the person who really controls it — are often not the same person. The beneficial owner is identified with a three-level hierarchical test (ownership, control, management) based on the information on shareholders and offices in the Registro Imprese (Italian Business Register), which remains consultable even though the Beneficial Ownership Register is currently not accessible to third parties.

Why the person who signs and the person who controls are often different people

It is a common mistake to assume that whoever appears as director or legal representative of a company is also the one who controls it economically. In practice, they often do not coincide: a director can be a manager with no stake in the capital, while real control — ownership of the shares, or the power to steer decisions — remains in the hands of one or more shareholders who stay behind the scenes, directly or through a chain of intermediate companies. Before signing an important agreement with a company, knowing who really controls it changes the assessment: does that person have other solid businesses, or do they already have other companies in difficulty?

The three-level hierarchical test

Identifying the beneficial owner follows a cascading test (art. 20 of Legislative Decree 231/2007), to be applied in order:

1. Ownership: the natural person who holds, directly or indirectly, a stake of more than 25% of the company's capital.
2. Control: if no one exceeds 25% of direct ownership, the person (or persons) who exercise a dominant influence through a majority of votes or contractual arrangements.
3. Residual criterion — management: if not even control can be clearly identified, the beneficial owner is the person who exercises management or executive powers in the company.

The three criteria are not equivalent alternatives to choose from: they are applied in order, moving to the next level only if the previous one identifies no one.

Where this information is found, and whether it is still public

The beneficial owner emerges from the Registro Imprese, kept by the Chambers of Commerce — a public register, not a restricted one. The Beneficial Ownership Register, a dedicated section of the Registro delle imprese (Business Register), is currently not consultable by third parties: according to the notice of the Chambers of Commerce of 4 August 2026, it remains suspended until the decision of the Council of State (details in the guide on the register). This does not make the information inaccessible: it can still be reconstructed from the data on ownership structures and corporate offices that companies must in any case file with the Registro Imprese.

Why it matters before signing an agreement, not only for anti-money laundering compliance

The beneficial owner was conceived as an anti-money laundering tool, but its practical value for anyone assessing a partner, a shareholder or a supplier goes further: it reveals whether the same person controls other companies — perhaps already in difficulty, or showing warning signs — and whether the person who is really deciding behind the agreement you are about to sign is the same as the one that appears on paper.

Corporate links: which other companies the business is connected to

The beneficial owner answers "who controls this company"; the corporate links (Decision and Investigation tiers) answer the complementary question — "which other companies is it connected to, through the same chain of ownership". When a relevant shareholder or director is itself a company, the report follows the chain up to 3 levels deep, including when an intermediate level is a foreign company (identified by an EU-format VAT number, VIES). The result is not only "who is in charge", but the map of companies linked to each other through that same ownership — useful for understanding whether a problem in one company of the group may also affect the one you are checking.

The limits of this check

It concerns exclusively natural persons with an office or a significant stake in the company searched — never data on natural persons unconnected with that role, in line with the Code of Conduct for commercial information [Codice di condotta per le informazioni commerciali] on which this processing is based (see the privacy notice for sources and the rights of the data subject). Veryfy applies this criterion with risk management algorithms that cross-reference the Registro Imprese and the other official databases — it is not a legal opinion on the ownership structure.