JADIS — Beneficial Ownership Register for Lithuanian Companies

AT A GLANCE

JADIS (Juridinių asmenų dalyvių informacinė sistema) is Lithuania’s mandatory register of beneficial owners of legal entities — every Lithuanian company must register the individuals who ultimately own or control it within one month of incorporation.
A company that has not registered its beneficial owners in JADIS, or whose JADIS data is inaccurate, is automatically suspended from commercial activity under Lithuanian law — meaning its contracts may be unenforceable and its bank account applications will be paused.
JADIS data must be confirmed annually and updated within 5 business days of any change in beneficial ownership — a share transfer, a change in the shareholder’s ownership percentage, or a change in the controlling individual must be reflected in JADIS promptly.
Banks and payment institutions check JADIS as the first step of their corporate account KYC process — an inaccurate JADIS registration is the single most common avoidable cause of bank account opening delays.
We register, update, and annually confirm JADIS data for all our corporate clients — treating JADIS compliance as a non-negotiable baseline requirement for every Lithuanian company we advise.

Short answer

JADIS is the Lithuanian Centre of Registers’ system for recording the ultimate beneficial owners (UBOs) of Lithuanian legal entities. Every Lithuanian company — UAB, AB, MB, and others — must register the individuals who own more than 25% of the company or who otherwise exercise effective control. Registration must happen within one month of incorporation, and data must be updated within 5 business days of any change. Failure to register results in automatic commercial activity suspension. We handle JADIS registration at incorporation, maintain it accurately as ownership changes, and confirm it annually — treating it as part of the standard corporate compliance package for every client.

What Is JADIS and Why Does It Exist

JADIS — Juridinių asmenų dalyvių informacinė sistema, the Information System of Participants in Legal Entities — is Lithuania’s national register of the beneficial owners of legal entities. It was introduced in 2019 under the requirements of the EU’s Fourth Anti-Money Laundering Directive (4AMLD) and subsequently updated to comply with the Fifth AMLD (5AMLD), which requires EU member states to maintain publicly accessible central registers of the beneficial owners of companies and trusts.

JADIS is managed by the Centre of Registers (Registrų centras) and is integrated into the same registry infrastructure as the Centre of Registers’ company register (JAR). The data in JADIS is publicly accessible — any person can search JADIS to identify the beneficial owners of a Lithuanian legal entity. This public accessibility is a core feature of the 5AMLD framework: transparency about who ultimately owns businesses is one of the EU’s primary tools for preventing money laundering and tax evasion through anonymous corporate structures.

The difference between shareholders and beneficial owners

The shareholders of a Lithuanian company are recorded in JAR — these are the legal owners of the shares. Beneficial owners are the individuals who ultimately own or control the company, which may differ from the legal shareholders in several common scenarios:

Holding company structure — a foreign holding company is the shareholder in JAR, but an individual ultimately owns the holding company; that individual is the UBO
Nominee shareholder arrangement — a nominee shareholder holds shares on behalf of another person; the underlying person is the UBO
Trust arrangement — a trust is the shareholder; the individuals who are settlors, trustees, or beneficiaries with effective control are the UBOs
Corporate chain — a chain of companies ends in an individual who owns more than 25% at the top of the chain; that individual is the UBO regardless of the number of intermediary layers
Control without majority ownership — an individual who exercises effective control over the company’s operations — even without owning more than 25% of the shares — may qualify as a UBO under the control criteria

 Who qualifies as an Ultimate Beneficial Owner (UBO)?

Under Lithuanian law implementing the 5AMLD, a UBO is: (a) any individual who directly or indirectly owns more than 25% of the company’s shares or voting rights; or (b) any individual who otherwise exercises effective control over the company — for example, through the right to appoint or remove the majority of the management board, through shareholder agreements, or through any other means. If no individual can be identified under these criteria after exhausting all possible means, the senior managing official (typically the director) is registered as the UBO by default.

JADIS Legal Obligations for Lithuanian Companies

Initial registration — within one month of incorporation

Every Lithuanian legal entity must register its beneficial owners in JADIS within one month of being entered in JAR (the Centre of Registers’ company register). For companies incorporated with us, we complete JADIS registration as part of the incorporation process — on the same day the company is registered. For companies incorporated without us, the one-month deadline is a statutory obligation that cannot be extended.

Annual confirmation — every January

Every year, each Lithuanian company must confirm in JADIS that its registered beneficial ownership data remains accurate and current. The annual confirmation must be made by the company’s director (or their authorised representative) by submitting a declaration through the Centre of Registers’ e-services portal. The confirmation deadline is not fixed in the law to a specific calendar date — the obligation is to confirm annually — but in practice the Centre of Registers sends reminder notifications in January and most companies confirm in the first quarter of the year.

Updating JADIS on changes — within 5 business days

When the beneficial ownership changes — through a share transfer, a capital change, a change in the ownership percentage, or any other event that alters who the UBOs are — the JADIS register must be updated within 5 business days of the change taking effect. The 5-day deadline runs from the date the change becomes legally effective — for a share transfer, from the date of the transfer deed, not from the date of the JAR filing.

The consequences of non-compliance

The consequences of JADIS non-compliance are specified in the Law on the Prevention of Money Laundering and Terrorist Financing and the Law on Legal Entities:

Automatic commercial activity suspension — a company that has not registered its UBOs in JADIS within the required timeframe is automatically suspended from commercial activity; it loses the legal capacity to enter binding contracts
Fines — administrative fines for JADIS violations range from €300 to €3,000 for responsible officials and €500 to €6,000 for legal entities
Bank account consequences — all Lithuanian banks and payment institutions check JADIS as part of their KYC process; a company with non-compliant JADIS status will have its account application paused or rejected
JAR suspension flag — the Centre of Registers may flag non-compliant companies in the JAR, making the suspension visible to counterparties and clients
Regulatory licensing impact — for companies applying for financial licences, crypto registrations, or other regulated activity authorisations, JADIS compliance is a prerequisite; non-compliance blocks the application

 Commercial activity suspension — what it means in practice

A company that is automatically suspended from commercial activity under the JADIS non-compliance rules loses its legal capacity to enter binding commercial contracts. In practice this means: any contract signed by the company during the suspension period may be challenged as unenforceable; counterparties who discover the suspension status may refuse to deal with the company; and regulatory authorities will flag the suspension during any licensing review. The suspension is lifted when JADIS registration is completed — but the gap period creates legal uncertainty that can be difficult to address retrospectively.

Common Beneficial Ownership Situations and Their JADIS Treatment

Determining who qualifies as a UBO and how to register them is straightforward for simple structures but requires careful analysis for more complex ownership arrangements. Below are the most common situations we encounter.

Simple structure — individual owner

One individual owns 100% of a Lithuanian UAB directly. JADIS registration: the individual is registered as the sole UBO with 100% ownership. This is the simplest case and takes a few minutes to complete through the Centre of Registers’ e-services portal.

Corporate shareholder — foreign holding company

A foreign company owns the Lithuanian UAB. The foreign company is the legal shareholder (registered in JAR), but JADIS requires the individual UBOs behind the foreign company to be registered. The JADIS entry must show: the foreign company (as the intermediate entity), and the individuals who own more than 25% of the foreign company (as the UBOs). If the foreign company is itself owned by another company, the chain is traced until the individual UBOs are identified. If the foreign company is listed on a regulated stock exchange, different rules apply.

Multiple shareholders with equal split

Three individuals each own 33.3% of the Lithuanian UAB. All three are UBOs because each owns more than 25%. JADIS registration: all three individuals are registered as UBOs with their respective ownership percentages. The total does not need to add up to 100% in JADIS — only the individuals who exceed the 25% threshold need to be registered.

Minority shareholder structure — nobody above 25%

Five individuals each own 20% of the company. None exceeds the 25% ownership threshold individually. In this case, JADIS requires analysis of whether any individual exercises effective control through other means — voting agreements, veto rights, or management control. If no UBO can be identified under either the ownership or the control criteria, the senior managing official (director) is registered as the UBO by default. This default registration must be clearly marked as a default (not as actual beneficial ownership) in JADIS.

Investment fund or institutional shareholder

An investment fund owns shares in the Lithuanian company. Investment funds are complex structures — the fund’s UBOs for JADIS purposes may be the fund’s general partners, the managing partners who exercise control, or the investors above the 25% threshold. The JADIS treatment depends on the type of fund and its governance structure. We advise specifically on fund-held structures as part of the JADIS compliance service.

Nominee shareholder

A nominee shareholder holds shares on behalf of another person under a nominee agreement. In JADIS, the underlying person — the beneficial owner of the nominee arrangement — is the UBO, not the nominee. The nominee arrangement itself should be documented in writing and available for inspection. Lithuania does not prohibit nominee arrangements, but they must be correctly disclosed in JADIS to avoid the non-compliance consequences.

Ownership Structure	Who Is the UBO?	JADIS Registration
Individual owns 100% directly	The individual	Register the individual with 100% ownership
Foreign company owns 100%	The individuals who own >25% of the foreign company	Register intermediate entity + UBO individuals; trace chain to individuals
Two individuals, 50/50	Both individuals (both >25%)	Register both with 50% each
Three individuals, 33.3% each	All three (all >25%)	Register all three with 33.3% each
Five individuals, 20% each	No individual >25%; director registered by default	Register director as default UBO; mark as default
Holding company chain (2 layers)	Individual at the top of the chain owning >25%	Register each intermediate entity + final individual UBO
Nominee shareholder	The person behind the nominee (the beneficial owner)	Register the underlying beneficial owner, not the nominee
Investment fund shareholder	Depends on fund type — managing partners or investors >25%	Analysis required; advise case by case
Listed company shareholder	Typically senior managing official (director)	Listed company exempt from tracing; register director as default

How JADIS Registration Works

JADIS registration is managed through the Centre of Registers’ e-services portal (www.registrucentras.lt). The registration must be made by the company’s director or their authorised representative using a qualified electronic signature. The process is entirely digital — no paper forms, no notary appointments, and no physical attendance at the Centre of Registers.

Identify all UBOs
Before any JADIS entry is made, we identify all individuals who qualify as UBOs based on the company’s ownership structure. For simple structures this is immediate. For multi-layer structures, we trace the ownership chain to the individual level and determine whether effective control criteria apply where no individual exceeds 25%.

Gather UBO documentation
For each UBO, we collect: full name, date of birth, country of nationality, country of residence, and the basis for qualification as a UBO (ownership percentage, or the specific control mechanism). For foreign UBOs, we confirm the accuracy of the information against their passport. For corporate intermediary entities in the ownership chain, we collect the entity’s registration details and country of incorporation.

Log in to the Centre of Registers e-services portal
The director (or their authorised representative with a valid QES) logs in to the Centre of Registers e-services portal at www.registrucentras.lt. The JADIS section is accessible from the legal entity’s profile page. For foreign directors without a Lithuanian electronic identity card, a power of attorney to a Lithuanian representative with a QES is required for JADIS submissions.

Submit the JADIS declaration
The beneficial ownership declaration is completed in the portal: for each UBO, the name, date of birth, nationality, country of residence, and ownership/control basis are entered. For multi-layer structures, intermediate entities are also entered. The declaration is signed with a qualified electronic signature and submitted. A submission confirmation is generated and should be retained.

Annual confirmation
Each year, the same process is repeated to confirm that the registered data remains accurate. The annual confirmation takes approximately 5–10 minutes for a simple structure. If any data has changed, the update is made at the same time as the annual confirmation. We manage annual confirmations for all corporate clients as a scheduled service in the first quarter of each year.

Post-change updates
When beneficial ownership changes — through a share transfer, a restructure, or any other event — we update JADIS within 5 business days of the change becoming effective. For companies where we manage the share transfer documentation, the JADIS update is coordinated simultaneously with the JAR share register notification.

 Can JADIS be completed remotely?

Yes — JADIS registration and all updates are completed through the Centre of Registers’ digital portal using a qualified electronic signature. No physical attendance at any office is required. For Lithuanian-resident directors with a Lithuanian mobile electronic identity (m.signature) or Smart-ID, the process is straightforward. For foreign directors without Lithuanian electronic identification, we manage JADIS submissions on their behalf under a power of attorney, using our team’s qualified electronic signatures. This is the standard approach for all foreign-owned companies we manage.

JADIS and Bank Account Opening

The connection between JADIS compliance and bank account opening is direct and practical. Every Lithuanian bank and payment institution — SEB, Luminor, Swedbank, Paysera, Revolut Business, and all others — checks JADIS as one of the first steps in their corporate account KYC process. The bank matches the JADIS beneficial ownership data against the ownership information provided by the applicant. Any discrepancy — data that is missing, inaccurate, or that has not been updated following a share transfer — pauses the application.

What banks look for in JADIS

Banks verify three things in JADIS: that the company is registered (not suspended); that the registered UBOs match the individuals named in the bank’s KYC documentation; and that the registration appears current (not many years old without any updates or confirmations, which suggests the company may not be actively managing its compliance). A recently registered or recently confirmed JADIS entry with accurate data that matches the bank’s documentation passes the JADIS check without delay.

The most common JADIS-related bank delays

The most common JADIS-related issues that delay bank account applications are:

No JADIS registration — company was incorporated without completing JADIS, often by founders who were unaware of the requirement
JADIS shows the corporate shareholder (holding company) as the UBO — the bank expects to see individuals, not companies, as the ultimate beneficial owners
Share transfer completed but JADIS not updated — the new shareholder is not reflected in JADIS after a share transfer
UBO data inaccurate — name spelling, date of birth, or nationality entered incorrectly in JADIS at initial registration
Annual confirmation overdue — JADIS data has not been confirmed for more than 12 months, raising a flag that the company’s compliance is not actively managed

 JADIS check before bank application — always

We check JADIS status and accuracy as the very first step of every bank account opening engagement. A JADIS issue discovered after the bank application has been submitted causes delays; a JADIS issue discovered before the application is submitted takes minutes to fix. This pre-application JADIS check is included in our bank account opening assistance service at no additional charge.

JADIS Compliance for Existing Companies

Many Lithuanian companies — particularly those incorporated before 2019 (when JADIS was introduced) or those incorporated without professional support — are either unregistered in JADIS, have inaccurate data, or have never confirmed their annual declaration. The legal consequences of non-compliance apply retroactively — a company that has been non-compliant for years is subject to the commercial activity suspension rule and the administrative fines regardless of when the non-compliance began.

How to check your company’s JADIS status

JADIS data is publicly accessible through the Centre of Registers’ company search at www.registrucentras.lt. Any person can search for a Lithuanian company by name or registration number and view its JADIS registration status. The search results show whether UBOs are registered, what ownership percentages are shown, and when the data was last confirmed. We conduct a JADIS status check as part of every new client onboarding — identifying any non-compliance before it becomes a problem.

Rectifying non-compliant JADIS registrations

Rectifying a non-compliant JADIS registration is straightforward for simple structures: the director logs in to the Centre of Registers portal and submits the required data. For complex structures — particularly multi-layer corporate ownership or nominee arrangements — the analysis of who qualifies as a UBO requires careful attention. We manage the rectification process, including the UBO analysis for complex structures, as part of our JADIS compliance audit service.

Limitation on retroactive liability

While JADIS non-compliance creates ongoing legal consequences, the practical enforcement of administrative fines has focused primarily on newly discovered non-compliance rather than historical gaps. Companies that proactively regularise their JADIS registration are in a materially better position than those who wait for enforcement action. We advise bringing JADIS into compliance as soon as the gap is identified — not waiting for an enforcement trigger.

JADIS Services Pricing

JADIS services are priced at modest fixed fees reflecting the administrative nature of the work — JADIS compliance is a mandatory legal requirement, and we price it accordingly.

Service	Price
JADIS initial registration — at incorporation Registering all UBOs at company incorporation; included in our incorporation packages	€400
JADIS initial registration — existing company (simple structure) Simple structure: direct individual owner(s); 1–2 UBOs with no intermediate entities	€450
JADIS initial registration — existing company (complex structure) Multi-layer corporate ownership; nominee arrangements; 3+ UBOs or ownership chain analysis required	€450
JADIS annual confirmation Annual declaration that registered data remains accurate; managed in Q1 each year	€80
JADIS update — single change (share transfer or UBO change) Updating JADIS following a share transfer or change in UBO identity or percentage	€450
JADIS update — complex restructure Multiple simultaneous changes; new ownership chain; complex intermediate entity changes	€500
JADIS compliance audit (existing company) Full review of existing JADIS registration for accuracy; written report on gaps; rectification	€300
UBO analysis advisory (complex structures) Legal analysis of who qualifies as UBO for funds, trusts, multi-layer structures, or PEP situations	€500
JADIS status check (standalone) Confirming current JADIS registration status and accuracy for a single company; no rectification	€50
Annual JADIS management retainer (all changes + confirmation) Annual confirmation plus up to 2 updates during the year; additional updates at €50 each	€150/year

Frequently Asked Questions

No — JADIS and the shareholders’ register (share register) are different records serving different purposes. The shareholders’ register (kept internally by the company and recorded in JAR) shows the legal owners of the company’s shares — the entities or individuals who hold shares directly. JADIS shows the ultimate beneficial owners — the individuals who ultimately own or control the company, which may be different from the legal shareholders where there are intermediate holding companies, nominees, or trusts. Both must be accurate, but they are maintained separately and contain different information.

If a Lithuanian company is owned (directly or indirectly) by a company whose shares are traded on a regulated stock exchange (such as the NYSE, LSE, or Nasdaq), the listed company is treated as the top of the ownership chain for JADIS purposes — the individual shareholders of the listed company do not need to be traced. Instead, the senior managing official (CEO or equivalent director) of the Lithuanian company is registered as the default UBO. The JADIS entry must clearly indicate the basis for this default registration. This exception applies only to companies listed on genuinely regulated exchanges — over-the-counter listings or exchanges in jurisdictions that do not have equivalent regulatory oversight do not qualify.

Register immediately. The commercial activity suspension consequence applies as long as the company remains unregistered — the longer the gap continues, the greater the cumulative risk. The practical steps: check your company’s JADIS status at www.registrucentras.lt; if unregistered, complete the registration through the Centre of Registers e-services portal as soon as possible; and consider a retroactive JADIS compliance audit to confirm there are no other outstanding compliance gaps. We offer an expedited JADIS registration service for companies in this situation — we can typically complete the registration on the same business day as instruction.

Yes — Lithuanian branches (filialai) and representative offices (atstovybės) of foreign companies registered in Lithuania must also register beneficial ownership data in JADIS. The UBOs of the branch are the same as the UBOs of the parent company — the individuals who ultimately own or control the foreign parent. Registering JADIS for a branch requires tracing the ownership chain of the parent company to its individual UBOs. We manage JADIS registration for branches and representative offices as part of our subsidiary/branch registration service.

JADIS is Lithuania’s national implementation of the EU’s 5AMLD requirement for member states to maintain central registers of the beneficial owners of companies. Similar registers exist in all EU member states — Companies House in the UK (the PSC Register), the Transparency Register in Germany, the RCS in France, etc. The EU’s current direction under the 6AMLD and the proposed Anti-Money Laundering Authority (AMLA) regulation is toward greater cross-border interconnection of these national registers, which will allow financial institutions to check beneficial ownership across the EU from a single query. Lithuania’s JADIS is already publicly accessible and integrated into the Centre of Registers’ infrastructure — it is well-positioned for this EU-level integration.

No — by definition, a beneficial owner under the 5AMLD framework must be a natural person (an individual), not a legal entity. While the ownership chain between the Lithuanian company and the ultimate individual may pass through multiple intermediate companies, the JADIS entry at the end of that chain must identify one or more human beings. Where a company is genuinely owned by another company with no individual holding more than 25% and no individual exercising effective control, the director of the Lithuanian company is registered as the default UBO — not the corporate shareholder. This default registration acknowledges that a human is always ultimately responsible for the company’s activities.

JADIS records beneficial ownership as a factual matter based on the legal structure of the company at the time of registration. If ownership is disputed — for example, if two parties are in disagreement about who owns certain shares — the legally effective ownership at the point of JADIS registration is what is recorded. Where a dispute is ongoing, we advise registering the ownership as it legally stands on the date of registration and updating JADIS if the dispute is resolved in a way that changes the UBO picture. A disputed JADIS registration does not resolve the underlying dispute but ensures the company meets its compliance obligations during the dispute period.

Ready to register or correct your JADIS data?

Contact us to check your company’s current JADIS status and confirm what, if anything, needs to be registered or updated. For new companies, JADIS registration is included in our incorporation service. For existing companies, we can typically complete a JADIS registration or update on the same business day as instruction.