Shareholding Structure Verification by Region – US, Canada, Europe, Asia

I went down a rabbit hole researching shareholding verification recently, and wow – each country does things completely differently!

Turns out checking who owns a US public company takes seconds online, but try the same in Hong Kong and you’ll hit walls. Canada just made it easy for all (more on this in a minute).

After digging through countless government websites and regulatory pages, I figured I’d share what I found. Honestly, I wish I’d had this guide when I started.

If you need to verify company ownership across borders, here’s the actual process in each region

Shareholding Structure Verification by Region – Quick comparison

Let me walk you through how verification actually works in each region…

Conducting Shareholding Structure Verification in the United States

When it comes to verifying shareholding in the US, it’s like they have two completely separate planets: public companies (super accessible) and private companies (nearly impossible).

Public Companies

For public companies, the SEC’s EDGAR system is seriously a dream. Anyone with internet access can look up ownership info:

1. Go to SEC.gov/edgar/search
2. Type in the company name or ticker symbol
3. Look for these specific forms:

• Schedule 13D/G: Shows anyone who owns 5%+ of shares (filed within 10 days of reaching that threshold)
• Form 4: Reports when company insiders (officers, directors, 10%+ owners) buy or sell shares
• Form 3: Initial filing when someone becomes an insider
• Proxy Statements: Annual disclosures with executive compensation and top shareholders

What I love about this system is how specific it gets. You can see exactly when major investors bought or sold shares, what they paid, and sometimes even their purpose if they file a 13D (which includes their reasons for investing).

Also, that 5% reporting threshold for public companies is lower than most countries’ 25% standard. This means you get much earlier visibility into who’s building significant positions in US public companies.

Private Companies

Now, for the frustrating part, it is private companies. So, for private companies, your verification options are still limited to:

• Check state business registries (but these only show registered agents and officers, not owners)
• Use commercial databases that aggregate public records
• Hire a due diligence firm if it’s really important
• Simply ask the company and request documentation (often your only real option)

Conducting Shareholding Structure Verification in Canada

Corporations Canada publicly shares information about “Individuals with Significant Control” (ISCs) – basically anyone who:

• Owns or controls 25% + of shares
• Has a significant influence over the corporation without necessarily owning shares

Here’s what you can access through their online search:

• Full legal name of the beneficial owner
• Dates they became and (if applicable) ceased to be an ISC
• Description of how they have control
• Address information

To verify this shareholding yourself:

1. Go to Corporations Canada’s online search
2. Enter the company name or corporation number
3. View the ISC information in the results

One important note from their website: they mention “the database of ISC information will take more than a year to be populated” since companies file this when their annual returns are due. So if you don’t see ISC info yet, it might just be timing.

What complicates things in Canada is that companies can be incorporated at either the federal or provincial level. While federal corporations now have this transparent system, provincial rules vary widely. Many states (e.g., Ontario, Quebec, etc) restrict access.

Conducting Shareholding Structure Verification in the European Union

The EU’s approach to shareholding verification is… complicated. In November 2022, the Court of Justice of the European Union (CJEU) ruled that public access violated privacy rights. Now, you need to show a “legitimate interest” to access ownership info in most EU countries.

But what counts as “legitimate interest”? That’s where it gets messy. Each country is interpreting this differently while they wait for the 6th Directive to clear things up.

Country-by-Country Breakdown

The situation varies dramatically depending on which EU country you’re dealing with:

What struck me about the EU approach is how they’re trying to balance two competing priorities:

1. Fighting money laundering and financial crime through transparency
2. Protecting individual privacy rights

The result is this middle-ground approach where access isn’t completely public but isn’t entirely restricted either. It’s definitely more complicated than “anyone can check” or “nobody can check” systems in other regions.

Conducting Shareholding Structure Verification in Asia

If you thought verifying ownership in the EU was challenging, welcome to Asia, where privacy is the priority and public access to ownership information is extremely limited.

Here’s a comprehensive comparison of major Asian financial hubs:

The ownership threshold is common among almost all nations, at 25%+.

Using Tech to Make Shareholding Structure Verification Less Painful

Verifying ownership structures across countries is a major headache. Just when you think you’ve figured out Hong Kong’s system, you’re thrown into Singapore’s completely different approach. 

This is where companies can use tech instead and ditch the manual hunt (especially if you want to conduct verifications at scale). Or even better, use tech in combination with human foresight so even unique cases can be addressed.

Modern verification solutions worth their salt offer one huge advantage.

They link directly to official registries in multiple countries, so you’re not juggling different government portals that seem designed to frustrate you. Mainly, 

These tools aren’t perfect. Coverage can be spotty in some places, and they sometimes miss nuances. But for routine checks across multiple countries, they can save countless hours of frustration and headaches. 

If you’re tired of the ownership verification runaround, check out Signzy’s demo to see how much easier this could be.