Beneficial ownership under the AMLR: the 25% rule, the RBO, and discrepancy reporting

If your firm is a designated person under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, you already deal with beneficial ownership every time you take on a corporate client. You identify the individuals behind the company, you check the Register of Beneficial Ownership, and you file the paperwork.

From 10 July 2027, the rules you apply come from a different place. Regulation (EU) 2024/1624 (AMLR) — the EU's directly applicable single rulebook — takes over the substantive beneficial ownership rules from the CJA 2010 framework. Its sister instrument, Directive (EU) 2024/1640 (AMLD6), reshapes the registers themselves. Most of your daily practice will feel familiar, but the definitions, thresholds and register machinery are all changing underneath you. Here is what that means in practice for an Irish firm.

The 25% rule, harmonised EU-wide

Under the AMLR, a beneficial owner is an individual with an ownership interest of 25% or more in a company, held directly or indirectly. The same threshold applies across all 27 member states, because the AMLR is a regulation: it applies directly, with no national transposition to vary it.

That harmonisation matters. Until now, beneficial ownership rules reached Ireland through directives transposed into national law, leaving room for differences between member states. From 10 July 2027, a firm in Dublin and a firm in Warsaw apply the same test — a real simplification if you act for cross-border group structures.

Two practical points to hold onto:

• Indirect ownership counts. You cannot stop at the first layer of a corporate structure. If your client company is owned by a holding company, you work up the chain until you reach the individuals at the top. Your file should show the chain, not just the final names.
• The threshold may fall for some sectors. The AMLR gives the European Commission power to set a lower threshold — to 15% or lower — for high-risk sectors by delegated act, following a review due by 2029. Nothing changes on day one, but your procedures should be written so a threshold change is a configuration update, not a rewrite.

What "obliged entity" means for you

Irish law calls your firm a designated person. The AMLR calls you an obliged entity. It is the same idea — a firm with AML obligations — but your refreshed policies, controls and procedures should use the AMLR's language and cite Regulation (EU) 2024/1624 as the governing instrument. A policy pack that still describes obligations purely in CJA 2010 terms will read as out of date to your supervisor after July 2027 — whether that is the PSRA, the Law Society of Ireland, a designated accountancy body such as Chartered Accountants Ireland, ACCA or CPA Ireland, the AMLCU, or the Central Bank of Ireland.

Your RBO duties today — and why they are the foundation

Since April 2021, designated persons in Ireland have had two concrete duties tied to the Register of Beneficial Ownership:

1. Obtain an RBO extract before entering a new business relationship with a corporate client.
2. Report discrepancies between what the register says and what your own customer due diligence finds, under Regulation 20(3)(b) of SI 110/2019.

Access to the RBO is tiered following the Court of Justice of the EU's ruling on public access. Competent authorities have full Tier 1 access. Designated persons get restricted Tier 2 access: your firm registers using the BEN3A1 form and pays a small fee — roughly €2.50 — per extract. There is no public API, so this is a manual, evidence-driven workflow: request the extract, store it, compare it against what the client told you, and record your conclusion.

These duties do not disappear in 2027. They are the base on which the AMLR builds. A firm whose RBO workflow is already tidy — extract obtained, comparison documented, discrepancy decisions logged — is most of the way to AMLR-ready on beneficial ownership.

Discrepancy reporting: the step most files miss

The discrepancy duty is where files tend to be thin. It is not enough to download the extract and move on. Your file should show three things:

• What the register said — the extract itself, dated.
• What you found — the beneficial ownership information the client provided and any structure analysis you did.
• Your comparison and decision — either "these match, no discrepancy" or "these differ, and we notified the Registrar," with dates.

A hypothetical example: your new client is an Irish limited company. The director tells you two siblings each hold 50%. The RBO extract lists only one of them. That is a discrepancy. You raise it with the client — perhaps a share transfer was never filed — and if the register is wrong, the discrepancy must be reported to the Registrar. Your file records the extract, the conflict, the conversation and the notification. That paper trail is exactly what a supervisor inspecting your CDD files will ask for.

Three registers, and an EU-wide network coming

Remember that Ireland has three beneficial ownership registers, and the right one depends on the client entity:

AMLD6 goes further: it connects member states' registers through the BORIS system and gives registrars new verification powers. Its register provisions are staggered — access provisions applied from 10 July 2025, and the core register articles and technical standards from 10 July 2026 — so this machinery is landing now, ahead of the AMLR itself. The direction of travel is clear: registers get more reliable, cross-border lookups get easier, and the discrepancy reports firms like yours file become a formal part of keeping the data honest.

What to do now

1. Check your firm's RBO access is in place — Tier 2 registration via the BEN3A1 form — and that whoever runs onboarding can actually pull extracts.
2. Audit a sample of recent corporate client files: is there an extract, a documented comparison, and a recorded discrepancy decision on each?
3. Make sure your procedures route trusts to CRBOT and relevant financial vehicles to the Central Bank register, not just everything to the RBO.
4. Update your CDD procedures to state the AMLR's 25% direct-or-indirect test and to cite Regulation (EU) 2024/1624, with a note that the Commission may lower the threshold for high-risk sectors.
5. For layered structures, require an ownership chain diagram on file, traced to the individuals at the top.
6. Set a diary point to re-check the position ahead of 10 July 2027, since AMLA technical standards and Irish transposition of Directive (EU) 2024/1640 are still being finalised.

Where CompliDesk fits

CompliDesk Ireland is built around exactly this workflow: a guided RBO check at onboarding, evidence storage for extracts and comparisons, a logged discrepancy decision on every corporate client, and policy templates written to the AMLR from day one. See the AMLR explainer for the full picture of what changes on 10 July 2027.