Ultimate beneficial owner
As a general rule, no. The RCTR search forms part of identifying the beneficial owner, but the sujeto obligado may not rely solely on the register's data — except in the cases where simplified due diligence legally applies.
The Central Register of Beneficial Ownership has existed since 2023, created by Royal Decree 609/2023 of 11 July and managed by the Ministry of Justice. Obliged entities must consult it — making it a duty added to your own check, not one that replaces it.
Two practical reasons mean a register search alone will not carry the file:
A missing or incomplete entry does not exempt you from requesting the documentation directly from the client — the deed of incorporation plus a certificate or extract from the commercial registry.
Legal basis: Real Decreto 609/2023; Ley 10/2010, Art. 4
Practical tip: Treating the RCTR as a substitute for your own due diligence is a typical mistake. It is a mandatory reference work, not a free pass — and a register search without the accompanying corporate documentation is half a check in the file.
AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.
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