Register discrepancies — the 14-day reporting duty

Article 24 turns every onboarding into a potential filing obligation, on a 14-day clock most firms have not built for. Under Regulation (EU) 2024/1624, obliged entities must report to the central registers any discrepancies they find between the information in those registers and the beneficial ownership information they collect themselves — without undue delay and, in any case, within 14 calendar days of detection. It also settles a question firms have argued over for years: the register is not the source of truth.

1. The duty, and what accompanies the report

The obligation bites on discrepancies between the central register and the information the entity collects under Article 20(1)(b) — identifying beneficial owners and verifying their identity — and under Article 22(7). The report must be accompanied by:

• the information obtained indicating the discrepancy;
• whom the entity considers the beneficial owners to be, and where applicable the nominee shareholders and nominee directors; and
• why.

2. The two cases you need not report

Article 24(2) provides a derogation. An entity may refrain from reporting and instead request additional information from the customer where the discrepancies:

Limb (a) is narrower than it first appears. Transliteration differences are excused only where identification is unaffected — so a name variant that makes it unclear which person is meant is not a typographical matter and must be reported. Limb (b) carries two cumulative conditions, and the second is a judgement the entity has to make and, sensibly, record.

3. Making 14 days workable

The clock runs from detection, which places the design burden on knowing when detection occurred. Three things make the duty operable:

• Timestamp the comparison, not the onboarding. The detection date is when the register was checked against the file — which may be at onboarding, at a periodic review, or when a register extract is refreshed. All three need to write the same field.
• Route the derogation decision, don’t bury it. Deciding not to report under Article 24(2) is a decision with conditions attached. If it is made silently by an analyst closing an alert, there is no record that the conditions were tested.
• Close the loop with the customer. The derogation permits requesting additional information from the customer instead of reporting — but if that request goes unanswered, the basis for not reporting may no longer hold.

4. The register is a check, not the answer

The structure of Article 24 settles the underlying question. If the register were authoritative, a difference would mean your file was wrong. Because the Regulation requires you to report the discrepancy and state whom you consider the beneficial owners to be, the register is a verification input that can itself be wrong.

That has a direct consequence for onboarding design: a process that populates beneficial ownership from the register has not performed the Article 22 identification at all, and by construction can never detect a discrepancy — because it has nothing independent to compare.

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Related: Beneficial owners · Spain’s beneficial ownership register · Transparenzregister in Germany