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CZ Legal Alert: Register of beneficial owners will not be public ͏

The Ministry of Justice has announced that, effective 17 December 2025, the Czech Register of Beneficial Owners will no longer be accessible to the general public. This decision follows recent court rulings that found unrestricted public access to the Register to be an unlawful interference with the right to privacy and the protection of personal data. According to the courts, the previous system was inconsistent with European law, which in turn prevented Czech authorities from effectively enforcing the obligation to register beneficial owners and rendered entries practically unenforceable.

Legal Alignment and Restoration of Functionality

However, by restricting public access, the Ministry of Justice is removing what it described as an unconstitutional situation. In this way, the Czech legal framework is brought back into alignment with European law. Therefore, the circumstances surrounding the Register of Beneficial Owners change significantly. Most importantly, all related registration processes are now fully restored. As a consequence, the authorities can once again rely on the Register as a functional legal instrument while simultaneously respecting privacy and data protection requirements.

Return of Sanctions and Enforcement Measures

Moreover, one of the most significant consequences of closing the Register to the public is the reactivation of sanction mechanisms. Until now, these sanctions have been largely ineffective. Once the Register is no longer public, the legal barrier to applying private-law sanctions is removed. In practice, this means that if beneficial owners are not registered, the prohibition on profit distribution will once again apply. Additionally, voting rights will be suspended. Furthermore, authorities will be able to initiate proceedings related to discrepancies and address offences under the Act on the Register of Beneficial Owners.

New Rules on Access to Register Data

Nevertheless, the Register of Beneficial Owners will not be completely closed. While members of the general public will only be able to access data after proving a legitimate interest, certain users will retain broader access rights. In particular, banks, credit institutions, and other obliged entities under the AML Act, as well as public authorities, will continue to use automated remote access. At the same time, individuals who are registered will be able to verify their status by logging in via their data mailbox. For these reasons, the Ministry strongly recommends reviewing and updating Register entries to avoid penalties and further complications.

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