The Hidden Shareholders: Exploring Sub-25% Ownership Through OSINT

Authors: Daniel Faram and Sham Ahmed

From 18 November 2025, new transparency rules require all directors and people with significant control (PSCs) of UK companies to verify their identities. This means:

• New directors will need to verify their identity before incorporation or appointment.
• Existing directors must confirm verification when filing their next annual confirmation statement.
• Existing PSCs will have 12 months to verify once the requirement begins.

This represents an important step toward improving corporate accountability and trust in UK business records. However, these rules only apply to individuals who meet the legal definition of a Director or Person of Significant Control (those holding more than 25% of shares or voting rights in a company).

That leaves a large population of legitimate but lesser-known shareholders who fall below the reporting threshold. While entirely lawful, these holdings sit outside both the PSC register and the upcoming identity verification regime, creating a blind spot in how ownership networks are understood.

Understanding the 25% Threshold

The 25% threshold was designed to balance transparency with privacy, identifying those with the greatest influence over a company. Anyone owning or controlling more than 25% of shares or voting rights must appear on the PSC register, making their relationship with the business public.

But those just below this threshold, those holding 24% or 25%, for instance, do not appear, even if they hold similar levels of influence when considered collectively across several companies or with other shareholders.

For investigators, analysts, and journalists, this sub-25% segment represents a valuable layer of context.

Mapping the Minority Shareholders

Within our wider dataset of UK shareholder information, Public Insights identified 2,800 shareholders across 1,585 businesses with ownership stakes of 24% to 24.99%. None of these individuals appear in the PSC register. We have created a map, available at https://publicinsights.uk/the-24-project, that visualises these records to provide an overview of the 2,800 shareholders just under the 25% PSC limit.

This subset forms part of a much larger dataset of over one million minority shareholders we identified who fall below the PSC threshold.

While there is nothing inherently suspicious about these holdings, they are a datapoint that can provide a red flag for crime.

Why This Matters for OSINT Investigations

For OSINT practitioners, sub-25% ownership data provides unique opportunities to identify relationships, influence, and hidden linkages not visible in standard PSC or director datasets or easily searchable via Companies House. Examples include:

• Network Mapping: Identifying repeated minority holdings across multiple businesses or regions can expose patterns of shared ownership.
• Due Diligence: Analysts can identify individuals with commercial interests that don’t appear in PSC or directorship records.
• Financial Investigations: Complementing verified PSC data with sub-threshold ownership helps build a fuller picture of control and investment.
• Investigative Journalism: Understanding who sits just below the disclosure threshold can shed light on financial ecosystems surrounding high-profile ventures or political interests.

In each case, context and corroboration are critical, and these holdings are only meaningful when combined with other public records.

Bridging the Transparency Gap

Following the introduction of identity verification, the accuracy of PSC and director data will increase, making it easier to trust official sources. Yet, by design, the sub-25% space will remain unverified.

This creates a transparency gap. Not one that indicates wrongdoing, but one that means ownership visibility is partial. For those conducting OSINT-driven financial or corporate research, it’s important to be aware of what sits beyond formal registries.

When combined with director disqualifications, planning records, professional registers, and rental and insolvency datasets, minority shareholder data can help build a more complete picture of influence within UK businesses.

A Responsible Use of Public Data

It’s important to emphasise that holding a sub-25% share is perfectly legitimate. Many shareholders intentionally maintain smaller stakes for partnership, tax, or investment reasons. The purpose of aggregating this data isn’t to cast suspicion but to highlight how public records, responsibly analysed, can enrich investigative understanding.

By acknowledging this layer of ownership, analysts can ensure their investigations reflect the full complexity of real-world networks.

Collaborative Research Invitation

As UK corporate transparency evolves, investigators must look beyond director data to understand the full picture of ownership and control. The introduction of identity verification for PSCs and directors will strengthen data integrity, but it won’t cover every type of shareholder.

Reviewing those just below the threshold offers a complementary view: one that reveals how influence, investment, and association extend beyond the most obvious reporting lines.

Through careful review of these public records, we can begin to understand not just who controls a company, but who connects the dots between them.

Public Insights will share a minority shareholder (sub-25%) dataset with verified UK investigators, journalists, and researchers interested in exploring this area further. If you identify patterns or connections of genuine investigative value, such as potential misuse of ownership structures or notable corporate linkages, and publish a responsible write-up of your findings, we’ll provide a complimentary Public Insights account to support your future work.