The Grand Chamber’s 21 May judgment in joined cases C-684/24 has redrawn the perimeter of beneficial ownership transparency inside the EU’s anti-money laundering framework, and the operational consequences are already filtering through national fiduciary registers across the Single Market. The Court held that Italian trust mandates — including fiduciary arrangements administered by trust companies without an actual transfer of ownership — fall squarely within the disclosure obligations of the Anti-Money Laundering Directive. The ruling closes an ambiguity that had allowed certain Italian fiduciary structures to be treated as outside the beneficial ownership perimeter and pulls them into the same transparency lane that governs more conventional trust vehicles.

The second pillar of the judgment is the Court’s reaffirmation that public access to beneficial ownership data, conditioned on a legitimate interest, is compatible with Articles 7 and 8 of the Charter of Fundamental Rights. The Grand Chamber framed the legislature’s transparency objective as a legitimate and important pursuit aimed at preventing money laundering and terrorist financing through increased visibility into ownership structures. The legitimate-interest gate — set down in the 2024 anti-money laundering package — has therefore survived its first major test inside the Court, even after the 2022 Sovim ruling that struck down indiscriminate public access.

The doctrinal weight of the decision sits in the way the Court has read the directive’s definition of beneficial ownership. By accepting that fiduciary mandates without transfer of legal title can still create the kind of control or benefit that triggers disclosure, the Grand Chamber has extended the reach of the framework to a category of arrangements that civil law jurisdictions had often treated as administrative rather than proprietary. The ruling will reverberate beyond a single Member State, since several capitals operate fiduciary or nominee structures that perform analogous functions and have been the subject of long-running enforcement disagreements with the Commission.

National registers are now expected to update their data architectures to capture the relevant fiduciary categories, and the Anti-Money Laundering Authority — AMLA — has signalled through its preparatory communications that it will use the ruling as part of its convergence work on register interoperability. Civil society organisations active in financial transparency, including Transparency International and Open Ownership, have welcomed the decision as a corrective to the post-Sovim narrowing of public access, while noting that the legitimate-interest test remains uneven across capitals.

The operational read for compliance teams inside banks, trust companies and corporate service providers is that the previously grey zone around Italian fiduciary mandates has now closed. Customer due diligence files will need to map the beneficial owners behind fiduciary arrangements with the same rigour applied to conventional trust vehicles, and the supervisory exchange of information between Member States will treat the Italian structures as in-scope. Several Italian trust companies have already requested guidance from their domestic supervisor on the practical timeline for register updates, and the central bank is expected to issue an implementing communication before the summer recess.

The political subtext of the ruling is the gradual recalibration of the Charter balance between privacy and transparency that the Court has been performing since the Sovim decision. The Grand Chamber’s willingness to validate conditioned public access, paired with its expansive reading of the beneficial ownership concept, suggests that the next round of contested cases — likely involving the practical operation of legitimate-interest filters and the cross-border interoperability of registers — will land with the transparency vector retained as the default starting point. The AMLA work programme for the second half of the year is now expected to absorb the doctrinal pivot into its convergence priorities.