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Beneficial ownership

ARES, the commercial register and the beneficial ownership register

Combine basic company data, representative authority and ultimate ownership without creating false assurance.

Redakce eAML.czLegal position: 2026-10-04Editorial check: 2026-10-04

Matching company names in three systems do not mean three completed checks. Distinguish where data originated and which question each source actually answers.

ARES as a starting point

ARES displays data from government source registers. It helps locate the business identifier, registered office, legal form and links. The Ministry of Finance expressly describes the data as informational; the overview is not a conclusion about beneficial ownership or proof of actual operations.

Make sure it is the correct entity rather than a similar name. A sole trader is not a separate legal entity. A business identifier helps distinguish entrepreneurs but does not replace identifying the natural person.

The commercial register and documents

The commercial register helps verify existence, registered office, governing body and representation rules. Shareholding information depends on legal form and what is actually recorded; the register does not reveal every possible owner or control agreement. Filed documents can substantiate constitutional provisions and changes.

Compare authority with the specific action. If two directors must act jointly, finding one name in the register is insufficient. Check any power of attorney and its scope too.

Beneficial ownership information

The beneficial ownership register contains specific information about natural persons and the basis for their status. It has not been openly public since December 2025; use an entitled access route. A registered beneficial owner need not be a director or direct shareholder.

Where the client has registration duties, use the register and at least another source. A company register or relevant document can be the additional source where it actually helps verify ownership status. Merely confirming the company name leaves ownership unverified.

Source independence and discrepancies

ARES and commercial applications may reproduce the same register. Matching displays are not new independent information. Record the original source, date and fact checked: existence, authority, shareholding or ultimate control.

For differences, establish the effective date and legal basis of the change. Ownership can change before register updates; a historical extract may not describe the present. Resolve persistent differences according to their significance for due diligence instead of choosing the most convenient entry.

Practical steps

  1. Locate the correct entity by identifier.
  2. Verify existence and representation through suitable registers and documents.
  3. Obtain beneficial ownership data and another source relevant to ownership.
  4. Record provenance, effective dates and resolution of differences.

Illustrative scenario

ARES locates the company, the commercial register shows two jointly acting directors, and beneficial ownership data plus constitutional documents substantiate two beneficial owners.

When the situation differs

An application loads ARES and its duplicate from another database. Staff call these two ownership checks although neither establishes the beneficial owner.

What to document

  • Client identifier and each source date.
  • Evidence of existence, representation rules and any authority granted.
  • A separate supported beneficial ownership conclusion.

Common pitfalls

  • Treating reproduced data as independent sources.
  • Confusing directors with owners.
  • Ignoring change dates and historical records.

Frequently asked questions

Is ARES prohibited for AML?

No. It is useful for orientation and basic data. Assess its nature and what it actually establishes.

Is the commercial register always a sufficient second source?

Only where relevant information actually helps verify the particular beneficial owner. A general company entry without ownership information may be insufficient.

Put this guidance into practice

Choose a record for the step you are working on. Adapt it to your profession and actual case.

Complete client information online

Where to go next

Sources and legal references

  1. Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
    § 8 odst. 2 písm. b), odst. 6; § 9 odst. 2 písm. b), c) · accessed 2026-10-04
  2. Zákon č. 37/2021 Sb. — aktuální znění e-Sbírky ↗
    § 16–17 · accessed 2026-10-04
  3. Ministerstvo financí: ARES ↗
    Popis ARES a informativní charakter údajů · accessed 2026-10-04
  4. Ministerstvo spravedlnosti: aktuální nápověda evidence skutečných majitelů ↗
    Přístup k údajům v evidenci; dálkový přístup · accessed 2026-10-04

Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.