While many of us were hopefully enjoying lazy summer days by the beach, Simon Harris was clearly hard at work in his office as he signed S.I. No. 406 of 2026 into law on the 7^th of August.  The official title for the statutory instrument is the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) (Amendment) Regulations 2026 and it effectively expands access to Ireland’s Register of Beneficial Ownership. Before anyone gets too excited, public access to the Register remains off the table.

The Regulations introduce a “legitimate interest” test. This means that people who can show a genuine interest in preventing or tackling money laundering, related offences or terrorist financing can apply to access beneficial ownership information. Certain groups are specifically recognised as having a legitimate interest, including journalists and media organisations, civil society organisations and academia, people likely to enter into transactions with a relevant entity, and certain AML/CFT authorities.

Those granted access can see information such as the beneficial owner’s name, month and year of birth, country of residence, nationality, and the nature and extent of their beneficial interest. In some cases, historical information covering the previous five years may also be available.

It is important to note, however, that the Register has not been reopened to the general public. Access remains tightly controlled and subject to an application and certification process, with safeguards in place where disclosure could put a beneficial owner at risk of fraud, harassment, violence or intimidation.

So, while most of us may have been making the most of the summer sunshine, the Register has been quietly opening its doors a little wider — just not quite to everyone yet.

Already this year the Registrar of Beneficial Ownership has brought prosecutions for failure to file beneficial ownership information with the Central Register of Beneficial Ownership before the Dublin District Court. The consequences for non-compliance can be severe and can attract a fine of up to €5,000 on summary conviction and up to €500,000 on indictment (and/or imprisonment). In 2024 (the latest up to date official figures available) 31 cases came before the District Court. 11 entities were convicted and fined and 20 entities pleaded guilty and had the Probation Act applied. Based on the number of prosecutions since just the start of this year, it seems certain that these numbers will be far exceeded in 2026.

As well as the risk of prosecution, the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 requires all ‘designated persons’ (e.g., banks, financial institutions etc) to inspect the Register of Beneficial Ownership as part of their customer due diligence before establishing a business relationship with a customer. They are obliged to report any discrepancies and non-compliance to the Registrar. Again the expectation is that the issuance of Discrepancy Notices will increase significantly this year.

KomSec can help and advise you on everything your company needs to be and remain compliant with Beneficial Ownership, allowing you to avoid Discrepancy Notices and possible prosecution.