The Real Cost of Cross-Border KYB in Europe Isn't the Fee

A Spanish exporter wants to check that a Hamburg-registered GmbH is the company its email signature claims it to be. The verification path in 2026 takes seconds and costs nothing. The exporter opens handelsregister.de, types the company name, downloads a structured extract in machine-readable XML. The fee schedule, last revised on 1 August 2022, is zero¹. The interface offers an English-language search.

That is the best case. It is also the only case among the five cross-border B2B verification scenarios examined for this article. Costs across the four other pairs — verifying a French SAS from Italy, a Polish sp. z o.o. from the Netherlands, a UK Ltd from Germany — range from €0 to roughly £78 for a same-day certified document. None are expensive in the historical sense. The headline KYB friction has migrated. It is no longer the fee schedule. It is the language barrier and the federation gap, and the EU legal instrument intended to close both does not apply until 31 July 2028.

Five country pairs, five workflows

Five paired transactions surface the operational reality of cross-border KYB in mid-2026. The matrix below covers, for each pair, the authoritative register on the destination side, whether an English search interface exists, the cost of a current extract under the 2026 fee schedules, the delivery speed and format, and whether the destination register is reachable through the EU's Business Registers Interconnection System (BRIS).

France charges, but barely. The Extrait Kbis — France's canonical company registration certificate — costs €3.20 for electronic delivery via Infogreffe under the 2026 fee schedule set by JORF n°0051 of 28 February 2026³. The document arrives near-instantly as a signed PDF, but in French only. Infogreffe operates no English-language interface. A French-resident user can search, pay, and receive the document inside a single browser session; a foreign verifier cannot read what arrives.

Poland costs nothing and follows a similar pattern. The Krajowy Rejestr Sądowy — the National Court Register, operated by the Ministry of Justice — provides current and full-history extracts for all sp. z o.o. and joint-stock companies at zero cost, in real time, through ekrs.ms.gov.pl⁴. The interface is Polish-only. The extract is Polish-only. From 1 April 2025, KRS-registered companies are required to maintain an e-Deliveries address⁵, which improves inbound Polish administrative communication and changes nothing for a Dutch verifier reading Polish for the first time.

The UK is the outlier on a different axis. Uncertified Companies House information has been free for years, downloadable in real time in English from a register with the highest navigability of any examined here⁶. The Companies House fee schedule revised on 1 February 2026 raised the certified-document fees — £15 for standard dispatch or £65 for same-day service on certified copies, with incorporation rising from £50 to £100 — but kept basic data fully free⁷. The friction in the UK case is structural rather than commercial: the UK is fully outside BRIS post-Brexit, with no EU-mandated mutual recognition of register documents and no e-Justice portal routing⁸.

BRIS: discovery, not delivery

BRIS connects 27 EU Member States and three EEA countries — Iceland, Liechtenstein, and Norway — into a single search layer that routes queries from any participating register to any other. The system has been operational since 8 June 2017 and now processes more than 20,000 messages per day between national registers, covering over 20 million companies and branches across the participating jurisdictions⁸⁹.

What BRIS delivers is discovery. A verifier in Italy who needs to confirm that a French SAS exists can use the European e-Justice portal to locate the company, view basic fields (name, registered office, legal form, status) with field labels rendered in the user's browser language, and confirm the entity. What BRIS does not deliver is the document. The e-Justice portal's own caveat is the strongest evidence: "you can only request information that the national registers provide free of charge. For documents against payment, the prices displayed on our portal are provided by the national registers and are only indicative and subject to change. To request any of those documents, please go to the national register's website"¹⁰.

Three constraints follow. Paid extracts must still be ordered at the national portal in the national language. The document content, as distinct from the field labels in the portal, is in the national language of registration in every case. And BRIS coverage is structurally limited to public and private limited liability companies, their branches, and the Societas Europaea form; partnerships, sole traders, and several non-corporate forms are partially or entirely absent¹⁰.

The UK exit from BRIS is the cleanest gap. Companies House does not appear in the e-Justice portal's list of connected registers. A German company conducting AML due diligence on a UK counterparty cannot route its query through BRIS and cannot rely on EU-mandated mutual recognition. The workflow has to be tracked separately and the documents accepted on the UK's own terms⁸.

Language is the friction tax

Of the five register interfaces examined, one offers a native English search to a foreign verifier: Germany's². The UK reads in English because the register is English by default, not because it has been translated for cross-border use. France, Poland, Spain, and Italy all require the verifier either to read the national language, to use machine translation on the search interface, or — for any document that will carry legal weight downstream — to commission a sworn translator.

Italy is the partial exception. Registro Imprese explicitly publishes an English-language visura — Company Registration Report — for the same price as the Italian-language version, at approximately €7 for a standard extract¹³. Italy is alone among the four non-English jurisdictions examined here in selling its standard register extract in English at the same price as the native-language version. The other three either offer no English version (France, Poland) or require a separate translation process to obtain one (Spain).

The LEI gap

The Legal Entity Identifier, issued under the Global Legal Entity Identifier Foundation (GLEIF) framework, was supposed to be the universal pan-jurisdictional identifier for legal entities. It exists. Almost no SME has one.

GLEIF's May 2026 data shows the active LEI population across the six jurisdictions examined in this article at a combined 1.14 million entities, against national company registers running into the millions per country¹⁴. Italy holds approximately 250,000 active LEIs against several million Italian companies; Germany 248,000 against roughly 3.5 million entities in the Handelsregister¹⁵; the UK 226,000 against approximately 5.6 million active companies in Companies House records¹⁶. The implied penetration rates are roughly 7% in Germany, 4% in Italy and the UK, 2% to 4% in France and Spain, and under 1% in Poland.

The UK is not in scope. Directive (EU) 2025/25 binds Member States and EEA participants. Companies House sits outside the BRIS perimeter and outside the EUID system. The 2028 reforms widen the cross-border KYB symmetry inside the EU/EEA and, by the same act, widen the asymmetry between EU/EEA and UK workflows.

What the search-first side looks like today

A search-first cross-border surface already exists at the user layer, even if the register layer below it stays fragmented until the directive enters application. B2Trust indexes 29M+ business entities across 32 countries, free and cross-border at b2trust.com. The coverage is built from imported registry data and is designed to address the discovery problem — which company exists, where, under what legal form, with what identifier — at the search layer, before any document is ordered from a national register and before any sworn translator is engaged.

The document layer still requires the national register. The fee schedule is what it is, the sworn translation is what it is, and the BRIS-versus-not-BRIS routing decision is what it is. The discovery step — the part of the cross-border KYB workflow that requires the verifier to know which national register holds the target company before any verification can begin — has a search-first surface already operating in 2026, ahead of the 2028 reforms.

The article opened with a Spanish exporter verifying a Hamburg GmbH. The conclusion stays the same: at the register layer, cost is gone. Language friction and the federation gap are not. The European Commission has legislated both away on a clock that does not tick until 31 July 2028. Until then, cross-border KYB in Europe is a translation problem dressed as a verification problem, and the work happens after the fee is paid, not before.

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Footnotes

1. Joint Register Portal of the German Federal States — Information document, Handelsregister.de. handelsregister.de/rp_web/div/info-lang/EN_Registerportal.pdf. Fee elimination confirmed against the Bundesministerium der Justiz reform of July 2022 (in force 1 August 2022). ↩

2. Unternehmensregister — The central platform for company data. unternehmensregister.de/en. ↩ ↩²

3. Légifrance — Journal Officiel de la République Française n°0051, 28 February 2026, Infogreffe tariff schedule. legifrance.gouv.fr. The €3.20 rate applies to the electronic delivery of the Extrait Kbis. ↩

4. European e-Justice Portal — Business registers in EU countries: Poland. e-justice.europa.eu. Access to KRS, including PDF extracts of current and full-history records, is free of charge. ↩

5. Polish government — e-Deliveries (e-Doręczenia) for entities entered in the KRS entrepreneurs' register became mandatory from 1 April 2025. gov.pl. ↩

6. Companies House Find and Update Company Information service — find-and-update.company-information.service.gov.uk. ↩

7. GOV.UK — Companies House fees are changing from 1 February 2026. gov.uk/government/news/companies-house-fees-are-changing-from-1-february-2026. Incorporation fee raised from £50 to £100; same-day certified copy raised to £65; standard certified copy £15. ↩

8. European e-Justice Portal — Business registers: search for a company in the EU. e-justice.europa.eu. BRIS coverage of 27 EU + 3 EEA Member States since June 2017. ↩ ↩² ↩³

9. European Commission Digital Building Blocks — BRIS Indicators Highlights dashboard PDF. ec.europa.eu. 20,000+ inter-register messages per day, 20M+ companies and branches covered. ↩

10. European e-Justice Portal — Business Registers: general information on find a company. e-justice.europa.eu. ↩ ↩²

11. Cour de cassation — Annuaire des experts judiciaires, traducteurs, interprètes (French sworn translator directory). courdecassation.fr. Sworn translation rates in France are not set by ministerial decree; each traducteur assermenté sets fees independently. The €50–€150 per-page range reflects published tariffs by Paris-area Cour d'Appel-registered sworn translators in 2025–2026. ↩

12. Linguaforum — National Court Register (KRS) translation pricing, accessed May 2026. linguaforum.eu. Standard KRS excerpt 4–8 countable pages (1,125 characters per page); price from 200 PLN for a typical excerpt. ↩

13. InfoCamere — Registro Imprese, visura ordinaria and English-language Company Registration Report. registroimprese.it. Italian and English versions of the standard visura are priced at the same level (~€7). ↩

14. GLEIF — Global LEI Index, data accessed via gleif.org reference data and the May 2026 snapshot. gleif.org/en/lei-data/global-lei-index. Active LEI counts by jurisdiction: IT 250,233; DE 248,252; GB 226,052; ES 188,473; FR 182,529; PL 41,590. Global active LEI population passed 3 million in Q1 2026 (3.4% QoQ growth; German renewal rate 74.5%) per GLEIF's "LEI in Numbers" Q1 2026 release. ↩ ↩² ↩³

15. Bundesanzeiger Verlag — Deutsches Unternehmensportal. deutschesunternehmensportal.de/en. Approximately 3.5 million entities in the German commercial register. ↩

16. Companies House statistical releases — UK active company population, 2024/25 annual register data. gov.uk/government/collections/companies-house-statistical-releases. Approximately 5.6 million active UK companies. ↩

17. Directive (EU) 2025/25 of the European Parliament and of the Council on the use of digital tools and processes in company law. EUR-Lex CELEX 32025L0025. eur-lex.europa.eu. Adopted 19 December 2024, OJ L published 10 January 2025; transposition deadline 31 July 2027; application date 31 July 2028. Introduces EUID, EU Certificate, apostille elimination for BRIS-verifiable extracts, and BRIS extension to BORIS (beneficial ownership) and IRI (insolvency). ↩ ↩²