Beneficial owner of shares: direct versus indirect

People search “beneficial owner of shares” when the member register and the person who benefits are different names. A direct holding and an indirect holding can both meet the ownership limb. Checked against AUSTRAC’s page on ownership and control and the initial CDD guide for a body corporate on 2 October 2026. This is general information, not legal advice. This page does not reproduce those guides. What 25% and control mean is what is a beneficial owner?. Where an ASIC extract stops is ultimate beneficial owner versus the ASIC extract. Sector context is /tranche-2.

Direct versus indirect

Direct means the individual is the registered holder. Their name is on this company’s member register, and they own the shares for themselves. Indirect means the individual owns or controls those shares through something else: another company, a nominee, or a trust. The beneficial owner is still an individual. A company in the middle is a step, not the answer.

A chain you can count

Jane owns 100% of HoldCo. HoldCo owns 40% of OpCo. OpCo’s register names HoldCo. Jane is not on it. She ultimately owns 40% of OpCo, so the ownership limb is in play even though the holding is indirect. A common way to see a split chain is to multiply through. If Jane owns half of HoldCo and HoldCo owns 60% of OpCo, her indirect stake in OpCo is 30%. That is still at or above 25%. The arithmetic is a sorting aid. It is not a second statute.

• Stop at a person. A holding company cannot be the beneficial owner you file. Order the next extract and keep going.
• Control can add a name the percentage misses. Someone under 25% can still control the votes or the board. That test stays on the beneficial-owner definition page. This page does not restate it.
• A small direct holder can still be out. Four people at 10% each, with no control story, are not four beneficial owners merely because they are on the register. Record the register. Explain who has control.
• Joint names need a basis. Two people on one line are not automatically 50% each. Use the register and what you were told. If the split is unclear, write that down and get advice before you email the wrong person.

Where this page stops

This page is the share distinction: direct versus indirect. It is not the trust answer. When the registered holder is a trustee, who you name under customer due diligence is who is the beneficial owner of a trust. The rules overview that points at the company file, the share file, and the trust file is AML beneficial owner rules for Tranche 2. The collection steps are how to perform beneficial ownership checks.

A members’ voluntary liquidation does not, by itself, open a personal file for every small holder. That boundary is MVL shareholder KYC. On a company formation there may be no extract yet. Proposed owners are still a direct-versus-indirect question. The service test for that engagement is AML for accountants: designated services.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. An individual further along the share chain is not bundled into the company figure. Confirm the live amounts on FreeAML pricing. FreeAML does not decide who the beneficial owner of the shares is, and it does not apply the control test.

Frequently Asked Questions