Beneficial owner registration in Denmark for foreign-owned companies

Every Danish company has direct owners on paper. Beneficial-owner registration asks a different question: which natural persons ultimately own or control the business?

For a founder-owned ApS, the answer may be straightforward. For a Danish subsidiary beneath foreign holding companies, different share classes or shareholder agreements, the company must look through the full chain, consider capital, votes and other control, document the reasoning and register the correct people.

More than 25% of capital or voting rights is an important indicator, but it is not the whole test. Control may also arise below that level through appointment rights, agreements or other arrangements. This guide explains the practical Danish process for a typical foreign-owned company and identifies cases that need specialist advice.

Beneficial ownership at a glance

On a small screen, swipe across the table to see all columns.

What is a beneficial owner in Denmark?

The Danish term is reel ejer. International groups often use ultimate beneficial owner or UBO.

The Danish Business Authority's current guidance describes a beneficial owner as a natural person who ultimately owns or controls a business through direct or indirect ownership of a sufficient part of the capital or voting rights, or through control by other means.

Three points matter:

• The analysis must end with one or more natural persons, not a parent company.
• A foreign company in the ownership chain does not stop the Danish review.
• Capital, votes and other control mechanisms must be considered together.

Nationality and residence do not decide the result. A person outside Denmark can be registered as the beneficial owner of a Danish ApS without moving to Denmark.

The 25% indicator is not a complete test

The detailed Authority guidance uses more than 25% of capital or voting rights as an indication of beneficial ownership. It also says that this is not a fixed threshold.

That produces four practical checks:

1. Calculate capital and votes separately. A person may own 20% of the economics but control 35% of the votes.
2. Combine relevant direct and indirect interests. Show each ownership route through the group.
3. Review people below the percentage indicator. Appointment rights, voting agreements or other influence can still create control.
4. Do not conclude from the cap table alone. Articles, shareholder agreements, pledges, nominees, options and other rights may change the answer.

Four founders with exactly 25% each do not cross a “more than 25%” indicator solely through their percentages. The company still has to review how decisions are actually controlled. Conversely, a smaller shareholder may qualify if that person can determine most board appointments or otherwise direct key decisions.

Where the outcome depends on minority vetoes, investor protections, trusts, foundations, nominees or disputed rights, obtain Danish legal or AML advice before filing.

Legal owner, beneficial owner and owner register

One ownership chart does not automatically satisfy every Danish ownership record.

On a small screen, swipe across the table to see all columns.

The official operational overview explains that a legal owner may be a person or company with at least 5% of capital or votes, while a beneficial owner is always a natural person. See the Danish Business Authority's ownership overview.

For an ApS owned 100% by a German GmbH, the GmbH is normally the direct legal owner. The Danish company must still look through the GmbH and any higher entities to identify the individuals who ultimately own or control the structure. The ApS must also keep its owner register aligned.

Which businesses register beneficial owners?

The Authority's detailed guide lists ApS, A/S, P/S, K/S, I/S and several other legal forms among the entities covered. The exact duty depends on the legal form and facts.

A Danish branch is listed among the forms that do not make a separate Danish beneficial-owner registration. That does not make the foreign parent's ownership irrelevant: banks, advisers, customers and authorities may still ask for the parent's UBO evidence. The distinction between a branch and a Danish company is explained in our company-type guide and Danish branch guide.

Listed-company structures, funds, foundations and similar arrangements can involve additional rules. They should not be decided from a general checklist alone.

Map the ownership and control chain

Use one dated working file that another reviewer can reproduce.

1. Start with the Danish entity

Collect the articles, owner register, current management list, share classes and recent transaction documents. Reconcile the direct shareholders to the legal-owner registration.

2. Trace every entity to natural persons

For each parent or holding company, obtain a current registry extract and supporting ownership records. Continue through foreign entities until the chain reaches individuals or a structure that requires specialist analysis.

3. Calculate capital and voting rights

For a standard chain, multiply the person's percentage at each level. If an individual owns 60% of a parent that owns 50% of the Danish ApS, the simple indirect economic interest is 30%. Add any separate direct or indirect route and calculate votes independently.

Arithmetic is evidence, not the entire conclusion. A person may control an intermediate company or the Danish entity through rights that are not reflected by the economic percentage.

4. Review other control

Check the articles and agreements for rights to appoint or remove management, direct votes, approve critical decisions, exercise pledged voting rights or act through a nominee. Distinguish ordinary minority protections from rights that can amount to actual control.

5. Record the conclusion and date

Write a short memo naming each person considered, the capital and voting calculations, other control rights reviewed, the registration conclusion and the effective date. Keep the source documents with the memo.

Worked examples

One foreign parent. A Danish ApS is wholly owned by a Dutch BV, which is owned 70% by one individual and 30% by another. Both individuals are above the percentage indicator for the Danish company, subject to the full control review.

Direct and indirect routes. One person owns 10% of the Danish ApS directly and another 25% through a holding structure. The combined 35% indicates beneficial ownership. The file should show both routes.

Four equal founders. Four people each hold exactly 25% of capital and votes. The company cannot stop at the percentages. It must review voting arrangements, appointment rights and actual influence before choosing a registration result.

Smaller investor with special rights. A 15% investor can appoint most of the board. That right may indicate beneficial ownership even though the percentage alone is below 25%. The precise conclusion depends on the full documents and should be legally reviewed where uncertain.

No beneficial owner and cannot identify are different

The official guidance describes three scenarios: the company has identified UBOs, the company has no UBO, or the company cannot identify its UBOs.

“No beneficial owner” may apply after a full review where no natural person ultimately meets the ownership or control test. “Cannot identify” is different: it means the company has exhausted reasonable avenues but still cannot establish the relevant person or information.

These are fallback outcomes, not shortcuts for a delayed shareholder reply or incomplete chart. The company should keep its request trail, registry documents, calculations and escalation notes. Under the applicable fallback, relevant management of the Danish entity is registered; that does not make those directors economic owners.

Registering a foreign beneficial owner

Ownership information is registered through Virk. For a new company, prepare the UBO data as part of the formation pack. For a later change, complete the analysis before submitting the update.

A foreign beneficial owner does not need a Danish CPR number merely to be registered. The filing requires the specified identity details and supporting documentation for a person without CPR. Check the current interface and document requirements at the time of filing, and use the actual start date of the ownership or control.

The person completing the filing needs the appropriate authority and access. The ownership role itself does not automatically mean that every UBO needs personal Danish digital access.

After submission, retain the receipt and reconcile the beneficial-owner registration with the legal-owner record, owner register, group chart and relevant bank or adviser KYC files. For the broader registration sequence, see our company-registration service and CVR and SE number guide.

Updates, annual review and evidence

Register changes as soon as possible after the company becomes aware of them. Do not wait for the next annual report.

Capital companies must review their beneficial-owner information at least annually and present the result when the central governing body approves the annual report. That review fits naturally with the year-end governance calendar described in our annual-report guide.

The Authority's guide says identification-attempt evidence is retained for five years after each attempt, and UBO documentation for five years after the beneficial ownership ends. A practical file normally contains:

• the dated group ownership chart;
• registry extracts and corporate documents for entities in the chain;
• capital and voting calculations;
• relevant articles, agreements, appointment rights, pledges or nominee documents;
• required identity evidence kept with appropriate access controls;
• the analysis memo, filing receipt and effective dates; and
• annual-review confirmations and action logs.

Access to UBO information and bank KYC

General-public access to Danish beneficial-owner information ended on 1 September 2025. The Authority's access guidance describes access for competent authorities, entities covered by AML rules and persons or organisations with a legitimate interest.

Restricted public access does not remove the company's filing duty, and it does not end bank questions. Banks and other regulated providers conduct their own customer-due-diligence review and may request the full ownership chain, identity documents, control analysis and source-of-funds information. A correct CVR filing is useful evidence, but it does not guarantee account approval. Our Danish business-bank-account guide explains how to prepare the wider onboarding file.

Common mistakes to avoid

• Registering the foreign parent company as the UBO instead of tracing to natural persons.
• Treating 25% as an absolute line and ignoring other control.
• Multiplying percentages but not reviewing votes, agreements or control of intermediate companies.
• Copying a group KYC result without checking the Danish entity's own rights and records.
• Using a fallback before reasonable identification work is complete.
• Forgetting the owner register and legal-owner update.
• Waiting for the annual report to register a change.
• Assuming restricted public access prevents authorities or regulated providers from seeing the information.
• Treating corporate UBO registration as proof of tax-treaty beneficial ownership; the tax concept requires its own analysis.

Prepare the filing and handover

Before filing, confirm the entity type, reconcile the direct owners, map the full chain, calculate capital and votes, review other control, identify any specialist questions and collect the current identity evidence. After filing, save the receipt, align related records and assign an owner for future transaction and annual reviews.

NordicEstab can coordinate the Danish registration pack, identify document gaps and help align the ownership information with company-formation and operational records under an agreed scope. Complex control, trusts, sanctions, investment screening and tax-treaty questions may require a Danish lawyer, tax adviser or other specialist.

General operational guidance checked against current official sources on 13 October 2026. The correct registration depends on the legal form, ownership documents and actual control rights. NordicEstab is an independent private consultancy, not the Danish Business Authority or a law firm.