Use and impact of public beneficial ownership registers: Denmark


Denmark’s BOT reforms followed a series of national scandals which increased public awareness of the role of corporate opacity and changing EU anti-money laundering (AML) requirements. In the early 2010s, a number of major scandals exposed how corporate vehicles were used to launder hundreds of billions of Danish kroner (DKK; USD 1 is equal to roughly DKK 7) over almost a decade, leading to substantial losses of domestic revenue.[8] Between 2009 and 2016, the number of reports of serious tax and VAT fraud counted by Denmark police more than doubled and, in 2016, the Panama Papers data leak further revealed the scale of tax and financial crimes (see, for example, Box 1)[9]. The Danish Customs and Tax Authority, Skatteforvaltningen (SKAT) invested significant resources to access and analyse the leaked data and investigate several hundred potential tax evasion cases. This led to over 30 court cases with the Danish State recovering millions in unpaid taxes.[10]

Box 1. How the Panama Papers revealed that corporate ownership secrecy enabled tax evasion in Denmark

Investigations into the Panama Papers revealed that the manager of a Panamanian company issued a power of attorney to a Danish football player and tax resident at the same time the company was registered. This ensured only the name of the manager appeared on the company’s registration documents, whilst giving the football player full control over the company. Danish media Ekstra Bladet reported that the tax authorities estimated the company owed DKK 7 million in unpaid corporation tax and interest.[11] The company was one of the 26 Panama-registered corporate clients of Nordea Bank, which SKAT suspected of being set up to allow real owners to hide behind nominee managers of corporate service providers in foreign jurisdictions to evade Danish taxes.[12] The role of corporate secrecy in these cases added to the momentum of BOT reforms.

Simultaneously in 2016 and 2017, the government introduced legislation requiring the disclosure of BOI as part of registering corporate vehicles to comply with the EU’s fourth AMLD, which required the implementation of central BO registers for legal entities in member states.[13] The DBA was designated as the authority in charge of collecting, publishing, and maintaining centralised BOI for corporate vehicles registered in Denmark and Greenland, integrated within the Central Business Register (CVR). BO data from the former Greenlandic Business Register (GER) was integrated into the CVR in 2018.[14] Several legislative updates in the following years have improved Denmark’s BOT regime, for example, ensuring the coverage of a wide range of corporate vehicles and aligning with rising EU standards.[15]

The fourth AMLD required central registers to be accessible to competent authorities, regulated entities, and members of the general public who could demonstrate a “legitimate interest”. However, the lack of guidance on what access based on legitimate interest should look like meant many critical non-government users, such as investigative journalists, were not always able to access BOI easily. Denmark implemented the fourth AMLD with Act No. 262 of 16 March 2016, and went beyond it by allowing access to BOI on the CVR by the public.[16]

In 2018, the fifth AMLD included a provision requiring all member states to make BO data available publicly, as Denmark had already done, without needing to demonstrate a legitimate interest in accessing that information. Yet, in 2022, a judgement by the CJEU concluded this provision in the fifth AMLD was legally invalid, as it constituted a disproportionate and unnecessary interference with the fundamental right to privacy and data protection for the purposes of AML in the EU.[17] It did, however, confirm that a number of non-government users, including journalists, civil society organisations, and researchers, had a legitimate interest in accessing the information to combat money laundering.[18] In response, a number of member states have suspended public access – and in some cases all non-government access – to their registers. Others, including Denmark, preserved public access to their registers.[19]

At the time of writing, negotiations about what effective legitimate interest access should look like in the EU under a sixth AMLD are expected to be agreed upon in 2024. Whatever access in Denmark, the EU, or beyond will look like in the future, it is essential that this is guided by actual examples of the use of BOI by a wide range of users; how this use can contribute to various policy aims – including but not limited to AML; and the specific user needs that enable impact.

“We are following the legislative updates closely. If the government starts requiring people to register online before accessing beneficial ownership data, it may represent a lot of work, and we wonder, who are you trying to protect? You may end up protecting more people who are trying to do something wrong by hiding their ownership interest, rather than people who have legitimate intentions to do so.”[20]

Henrik Kristian Christensen, Marketing Manager, BiQ


[8] Jens Fuglsang Edelholt, “Udbyttesagen: To britiske statsborgere tiltalt for svindel for mere end ni milliarder kroner”, Anklagemyndigheden (Prosecutor’s office), 7 January 2021,; Kirstin Ridley, “Shah lawyer urges top UK court to block $1.8 billion Danish ‘cum-ex’ case”, 5 July 2023, Reuters,; Gabriella Gricius, “The Danske Bank Scandal is The Tip of the Iceberg”, Foreign Policy, 8 October 2018,; Holger Roonemaa, Simon Bowers, Dragana Peco, Elena Loginova, and Graham Stack, “Rinse, Profit, Repeat: How a Small Team of Estonians Turned a Danish Bank into a Laundromat”, Organized Crime and Corruption Reporting Project, 21 September 2020,; “Newsletter – New requirement regarding registration of beneficial owners”, Nyborg & Rørdam Advokatfirma, n.d.,

[9] Statsadvokaten, Money Laundering in Denmark: National Risk Assessment 2018 (Copenhagen: Statsadvokaten, 2018),

[10] Luke Harding, “Panama Papers: Denmark buys leaked data to use in tax evasion inquiries”, The Guardian, 7 September 2016,; Jacob Gronholt-Pedersen, “Denmark seeks damages from firms exposed of tax evasion in Panama Papers”, Reuters, 3 April 2029,; Christian Wenande, “SKAT cracks down hard on Danes in Panama Papers”, The Copenhagen Post, 9 February 2018,

[11] Andreas Munk and Manne Scheef, “Afsløring: Allan Nielsen har gemt millioner i Panama”, Ekstra Bladet, 23 March 2022,

[12] Andreas Munk, “Fortrolige dokumenter: Nordea står bag skattesvindel”, Ekstra Bladet, 21 October 2022,

[13] LOV nr 262 af 16/03/2016, Retsinformation, n.d.,

[14] “All Greenlandic companies are now to be registered in the CVR register”, Horten, 1 January 2018,

[15] BEK nr 488 of 18/05/2017, Retsinformation, n.d.,; 2018/1 LSF 205, Retsinformation, n.d.,; LBK nr 1052 of 16/10/2019, Retsinformation, n.d.,; LBK nr 2020 of 11/12/2020, Retsinformation, n.d.,; LBK nr 1062 of 19/05/2021; LBK nr 1952 of 11/10/2021, Retsinformation, n.d.,

[16] BEK nr 488 af 18/05/2017, Chapter 16, Section 37, PCS, 3; Financial Action Task Force (FATF), Anti-money laundering and counter-terrorist financing measures – Denmark, Fourth Round Mutual Evaluation Report (Paris: FATF, 2017), 9,

[17] “Judgment of the Court (Grand Chamber), 22 November 2022, (Reference for a preliminary ruling – Prevention of the use of the financial system for the purposes of money laundering or terrorist financing – Directive (EU) 2018/843 amending Directive (EU) 2015/849 – Amendment to Article 30(5), first subparagraph, point (c), of Directive 2015/849 – Access for any member of the general public to the information on beneficial ownership – Validity – Articles 7 and 8 of the Charter of Fundamental Rights of the European Union – Respect for private and family life – Protection of personal data)”, Curia case law, 2022,

[18] For more information, see: Kiepe, “Striking a balance: Towards a more nuanced conversation about access(es) to beneficial ownership information”.

[19] Maíra Martini, “Why Are EU Public Registers Going Offline, and What’s Next for Corporate Transparency?”, Transparency International, 25 November 2022,

[20] Interview with Henrik Kristian Christensen, Marketing Manager, BiQ, 20 September 2023.

Next page: Denmark’s comprehensive approach to beneficial ownership transparency