Is a director a beneficial owner?

People search “is a director a beneficial owner” when a suburban accounting firm sees two directors on an extract and types both in as beneficial owners. Checked against AUSTRAC's page on ownership and control on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The company version of the test is beneficial owner of a company. The definition page is what is a beneficial owner?. The sector map is /tranche-2.

Office is not ownership

The question is a director a beneficial owner comes up the moment an extract lists two names under officeholders. Those names are directors. Beneficial owners are individuals who ultimately own 25 percent or more, or who control the company another way. The same human can be both, and the titles are not the same reason.

A suburban firm that copies every director into the beneficial-owner line will over-collect on some files and under-collect on others. The silent shareholder who is not a director never appears. The executive director with no stake appears for the wrong reason.

• Read the holding first. A director who owns 40 percent is a beneficial owner because of the 40 percent.
• Do not promote the title. A director at 10 percent, with no control, is still a director. That is not the ownership limb.
• Control can still add them. If that director can appoint the board, control may put them on the list even under 25 percent. The control test is on the definition page.
• No one on the list is a different problem. The program, not this page, says whether you then identify a senior managing official.

Four companies, four answers

The extract answers who the directors are. It does not answer the beneficial-owner question unless you also know the holdings and the control story. Write the reason next to the name so a later reader can see office, ownership, or control.

Where the director question stops

This page answers whether the office makes someone a beneficial owner. It is not the full company procedure. That procedure is beneficial owner of a company.

It does not say how many people can be on the list at once. More than one is normal, and that question has its own page.

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. Verifying a director is a separate decision from verifying a beneficial owner, and neither check is included in the company KYB fee. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that every director is a beneficial owner or apply the control test for you.

Frequently Asked Questions