In July I graded European registers by a single criterion: how much due-diligence data I could reach without paying for a single extract. Estonia got top marks; Germany came close to failing. The least accessible data belonged to exactly the countries people ask about most.

Since then, movement has returned to European registers. They are opening earlier than I expected. But when I went through what is actually opening, it turned out to point somewhere other than what I measured – and that difference is more interesting than the news itself.

What actually changes

Journalists, academics and civil society organisations whose work concerns money laundering or its predicate offences gain a presumed legitimate interest in accessing beneficial ownership registers. They no longer have to demonstrate it case by case. The access is meant to cover all 27 national registers.

Two dates go with it. The provisions on register verification and data quality were to be transposed into national law by 10 July 2026. And by 10 November 2026, registers must answer legitimate-interest requests within twelve working days, extendable by a further twelve in exceptional cases. By the same date, a machine-readable format and API access for authorised users become mandatory.

Why this does not fix my report card

Here is the distinction this piece exists for. My grades concerned company register data: whether a company exists, its officers, registered address, history, financial statements. What is opening now are beneficial ownership registers. Those are two different databases, often run by different institutions under different rules.

A country can have an exemplary beneficial ownership register while still selling company extracts as paid PDFs. And the other way round. So "registers are opening" says nothing on its own about whether my near-failing grade improves.

A second clarification: presumed legitimate interest is not the same as public access. It simplifies the process for a defined group – journalists, academics, anti-money-laundering NGOs. Anyone outside that group still has to demonstrate interest. A tool built on freely available data may therefore get nothing out of this at all.

One part could still change something: the mandatory machine-readable format and API. That is the only provision that speaks about an interface rather than an entitlement.

A deadline in days is not an interface

"An answer within twelve working days" sounds like a guarantee. From the point of view of someone building a tool, it is a description of a form, not an interface.

Twelve working days is, with ordinary weekends and holidays, roughly two and a half weeks, extendable to five. You cannot run a counterparty check before signing a contract at that rhythm. So if some countries satisfy the letter of the rule by opening an inbox with a deadline, they comply formally and in practice nothing changes.

The gap between "complied" and "usable" is exactly what I ran into in July with several countries. The German paradox from that report card still stands: the largest economy, the least accessible data.

What I will test, and how

I do not want to claim nothing will improve – that would be the optimistic press release in reverse. I want to measure it the same way I measured in July, so the two grades are comparable.

The test is simple, and taken from an ordinary user's position rather than an authorised one:

1. Does the register return structured data (JSON/XML), or PDF and HTML?
2. Is there an API, or only a form?
3. What comes back with no registration and no demonstrated interest?
4. How many countries answer in seconds rather than days?

The date is fixed: 10 November 2026. Until then what I wrote in July stands, and I have no reason to revise it in advance.

What would show I was wrong

First, I claim that for the countries I graded worst, access to company register data will not change by November, because the new obligations target a different database. Any of those countries publishing a machine-readable company extract free of charge before November refutes it.

Second, I claim that at least some countries will meet the obligation with a form and a deadline rather than an API. A November in which all of them have working APIs for authorised users refutes it.

I would like both to be refuted. But I am writing them down now, while it is still open – because a prediction made after the result is not a prediction.