BENEFICIAL OWNERSHIP TRANSPARENCY: A COMPARATIVE ANALYSIS OF INDIA'S SIGNIFICANT BENEFICIAL OWNER REGIME AND THE UNITED KINGDOM'S PERSONS WITH SIGNIFICANT CONTROL REGISTER
Vanshika Jain, Final Year , Student pursuing law (LLB) at Lancaster University
India’s Significant Beneficial Owner (SBO) regime and the United Kingdom’s Persons with Significant Control (PSC) register share a common foundation in the Financial Action Task Force’s standards on beneficial ownership transparency, yet they diverge materially in relation to disclosure thresholds, verification design and enforcement practice. This article undertakes a comparative-doctrinal analysis of the two regimes, using primary legislation, statutory rules, regulatory materials, judicial proceedings and institutional reports to assess how each jurisdiction identifies, records and verifies the natural persons who ultimately own or control corporate vehicles. It examines India’s shift from a 25 per cent disclosure threshold to a 10 per cent SBO threshold under the 2019 amendments, the enforcement implications of the LinkedIn/Nadella proceedings, and the United Kingdom’s historically self-reporting-based PSC register, which is now being strengthened through the Economic Crime and Corporate Transparency Act 2023 and mandatory identity verification at Companies House. The article further identifies a cross-border compliance mismatch created by the interaction between India’s lower SBO threshold and the United Kingdom’s 25 per cent PSC and Register of Overseas Entities framework, particularly where Indian-controlled holding structures are used in relation to UK property. Using the Nirav Modi proceedings as an illustration of the limits of bilateral transparency where ownership chains move through third jurisdictions, the article argues that threshold rules alone cannot produce reliable beneficial ownership transparency. It recommends three connected reforms: closer threshold alignment, independent verification of beneficial ownership filings, and formalised regulator-to-regulator information-sharing mechanisms between India and the United Kingdom.
| 📄 Type | 🔍 Information |
|---|---|
| Research Paper | LawFoyer International Journal of Doctrinal Legal Research (LIJDLR), Volume 4, Issue 3, Page 783–799. |
| 🔗 Creative Commons | © Copyright |
| This work is licensed under a Creative Commons Attribution-NonCommercial 4.0 International License . | © Authors, 2026. All rights reserved. |