The Czech Beneficial Owner Register: Suspension, Repair, and Return of Enforceability

In two landmark rulings issued in August 2025, the Czech Supreme Court held that the existing legal framework governing the registration of beneficial owners is incompatible with EU law, in particular the rights to privacy and protection of personal data. As a result, the Czech beneficial ownership regime entered a temporary state of suspension.

During the interim period between August and December 2025, the obligation to register beneficial owners formally remained in place; however, it was unenforceable in practice, and no public or private sanctions could be imposed for non-compliance. Although the underlying legislation has not been formally amended, the conflict with EU law was addressed on an administrative level when the public part of the Register of Beneficial Owners was taken offline as of 17 December 2025. Following the removal of public access to beneficial ownership data, the registration obligation regained enforceability, and sanctions for non-compliance, including fines, suspension of voting rights, and restrictions on profit distributions, are once again applicable.