Court of Justice 18 December 2025, C-798/24 (A et autres v Latvijas Republikas Saeima.)

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Advocate General Norkus opines that Article 14(d)(ii) of Directive 2017/1132 cannot be interpreted as requiring Member States to disclose information on every shareholder of a public limited company, as the term 'take part in the administration, supervision or control of the company' refers to persons appointed to specific bodies or functions within the company, not to shareholders by virtue of their shareholding status alone. The AG further opines that the GDPR, in particular Articles 5 and 6, precludes national legislation—such as the contested Latvian provisions—that makes personal data of all shareholders of a public limited company freely accessible to any member of the general public without requiring demonstration of a legitimate interest, on the grounds that such unrestricted access constitutes a serious and disproportionate interference with the fundamental rights guaranteed by Articles 7 and 8 of the Charter of Fundamental Rights of the European Union. The AG draws an analogy with the Court's judgment in Luxembourg Business Registers (C-37/20 and C-601/20) and concludes that the three purposes invoked by the Latvian legislature—ensuring a transparent business climate, preventing money laundering and terrorist and proliferation financing, and enforcing sanctions—could reasonably be achieved in an equally effective manner through a procedure requiring demonstration of a legitimate interest, such as the restricted information access procedure under Latvian law.AI