Last reviewed October 7, 2026 · By the NYBACS advisory team
Short answer
It depends on the registry model. A US state issues a filed certificate or articles that prove the company exists but rarely show who owns it, and the EIN letter comes separately from the IRS. The UK, India, Singapore, France, Germany and the Netherlands issue registry records or extracts that also list directors and often shareholders, while UAE authorities issue a trade licence plus constitutional and share documents.
Key takeaways
- A US formation filing proves existence, not ownership: ownership is evidenced by internal records such as the stock ledger, share certificates or the LLC operating agreement.
- The US EIN confirmation (IRS notice CP 575) is a separate federal document and is not part of the state formation package.
- UK, Singapore, India, French, German and Dutch registries issue extracts or profiles that name directors, so a recent registry printout often does more KYC work than a US certificate.
- In the UAE the trade licence is the core operating document, and the free zone or mainland authority that issues it determines the rest of the package.
- Banks, auditors and foreign authorities usually ask for a recent extract or certified copy, so a formation pack needs refreshing rather than filing once.
Why no two countries hand you the same formation pack
Company registries are built on different models. US states run filing registries: the Secretary of State or Division of Corporations accepts a short public document, stamps it and returns it. Officers, shareholders and members are usually absent from that filing, so ownership lives in documents the company keeps itself.
The UK, Singapore and India run disclosure registries that hold and publish directors, shareholders and, in the UK and Singapore, beneficial owners or persons with significant control. France, Germany and the Netherlands add a notarial layer: articles are executed before a notary, and the commercial register publishes an extract that third parties rely on. The UAE works on a licensing model, where the authority that licenses the activity is also the registrar.
The practical consequence is that a document which fully satisfies a bank in Amsterdam may be only one piece of the evidence a US bank or Indian parent auditor expects from a Delaware company, and vice versa.
Side-by-side: the core document in each country
| Country | Core existence document | Issued by | Shows directors? | Tax ID issued with formation? |
|---|---|---|---|---|
| United States | Filed Certificate of Incorporation / Articles of Incorporation (corp) or Certificate of Formation / Articles of Organization (LLC) | State filing office | Usually not | No: EIN is applied for separately with the IRS |
| United Kingdom | Certificate of Incorporation with company number | Companies House | Yes, on the public register | No: HMRC registration follows separately |
| UAE | Trade licence, plus certificate of incorporation in most free zones | Free zone authority or mainland economic department | Licence names the manager; MOA and share certificate show owners | No: corporate tax and VAT registration are separate with the Federal Tax Authority |
| India | Certificate of Incorporation with CIN | Ministry of Corporate Affairs (Registrar of Companies) | Yes, via MCA master data | Yes: PAN and TAN are allotted through the SPICe+ incorporation form |
| Singapore | Notice of incorporation, UEN and ACRA Business Profile | ACRA via BizFile | Yes, on the Business Profile | The UEN is used with IRAS; GST registration is separate |
| France | Extrait Kbis | Greffe of the commercial court (RCS) | Yes, legal representatives | SIREN/SIRET numbers are allocated on registration |
| Germany | Handelsregisterauszug (commercial register extract) | Local court register (Amtsgericht) | Yes, managing directors | No: tax number comes from the local tax office after registration |
| Netherlands | KvK uittreksel (Business Register extract) | Netherlands Chamber of Commerce (KvK) | Yes, directors and authorised signatories | VAT and tax numbers follow from the KvK registration |
India appears here for comparison only. NYBACS does not incorporate or provide entity services in India; our role starts when an Indian business is setting up abroad.
What a complete US formation pack actually contains
Because the state filing says so little, a usable US pack is mostly assembled by the company and its advisers:
- State-filed document with filing date and file number (certified copy if it will be used abroad).
- IRS EIN confirmation (CP 575, or a 147C verification letter if the original is lost).
- Incorporator statement or organizer consent appointing the first directors or confirming members.
- Bylaws (corporation) or operating agreement (LLC) setting out governance and signing authority.
- Initial board or member resolutions covering share issuance, officer appointments, bank account opening and fiscal year.
- Stock ledger and share certificates, or a membership schedule: the documents that actually prove ownership.
- Registered agent details and, later, a certificate of good standing when a bank or counterparty wants current status.
If the owner is a foreign company, a short structure chart linking the US entity to its ultimate individual owners saves repeated questions from banks and auditors.
Local quirks in the UK, UAE, Singapore and continental Europe
- UK: The certificate never changes, but the public register does. Directors and people with significant control appear on Companies House, and every company files a confirmation statement (CS01) at least once every 12 months to confirm that information. From 18 November 2025, new directors and PSCs must have their identity verified with Companies House.
- UAE: Expect a trade licence with an expiry date, a memorandum of association, a share certificate, a lease or flexi-desk agreement and, if visas are planned, an establishment (immigration) card. Licences are renewed annually, so an expired licence undermines every other document.
- Singapore: ACRA issues a notice of incorporation and a Business Profile that can be purchased again at any time; the constitution and registers of members and controllers are kept by the company and its secretary.
- France, Germany, Netherlands: The notarial deed of incorporation, the articles and the shareholder list (the German Gesellschafterliste) sit alongside the register extract. Counterparties commonly ask for a Kbis or register extract issued within the last three months.
Existence, ownership, authority and tax status are four different proofs
Most rejected KYC packs fail because one document is asked to prove something it does not cover. Before sending a pack, check which of these four questions each recipient needs answered:
- Does the company exist and is it current? Registry certificate or extract, plus a good standing certificate in the US.
- Who owns it? Share register, stock ledger, operating agreement, MOA or registry shareholder data, traced through to individuals.
- Who can sign for it? Resolutions, a register extract listing representatives, or a certificate of incumbency.
- Is it registered for tax? EIN letter, PAN/TAN, UEN with IRAS, or the relevant VAT number.
When the documents will be used in another country, add the certification layer: certified copies, notarisation, and an apostille or embassy legalisation depending on the destination.
Common mistakes to avoid
- Sending only US Articles of Organization to a bank or parent auditor and expecting them to show who owns the LLC.
- Treating the EIN letter as a state document and forgetting to keep the original CP 575 safe.
- Using a Kbis, KvK or Handelsregister extract that is several months old when the recipient requires a recent one.
- Letting a UAE trade licence lapse, which makes the MOA and share certificate unusable for banking until it is renewed.
- Never preparing a stock ledger or share certificates after forming a C-Corp, leaving no formal ownership evidence.
- Assuming a UK certificate of incorporation reflects current directors, when only the Companies House register does.
Documents and records to prepare
- State-certified formation document (US) or registry certificate or extract (other countries)
- IRS EIN confirmation letter (CP 575 or 147C) for US entities
- Bylaws, operating agreement, constitution or articles of association
- Initial resolutions appointing directors and officers and issuing shares
- Share register, stock ledger or membership schedule and share certificates
- Ownership structure chart down to individual beneficial owners
- Current good standing certificate or recent registry extract
NYBACS 360° support
How NYBACS helps
- Assembles a complete US formation pack, including the internal ownership and authority records the state filing does not cover.
- Maps which document in each jurisdiction proves existence, ownership, signing authority and tax registration for a specific bank or auditor request.
- Orders certified copies and good standing certificates and coordinates notarisation and apostilles when US documents are needed abroad.
- Reconciles names, addresses and ownership details across the state filing, IRS records and bank records so the pack tells one consistent story.
Frequently Asked Questions
Does a Delaware company receive share certificates from the state?
No. Delaware files the Certificate of Incorporation; share issuance is a company action recorded in board resolutions, the stock ledger and, if used, share certificates. The company or its advisers prepare these after incorporation.
What is the US equivalent of a Kbis or a Companies House extract?
There is no single equivalent. A certificate of good standing from the state shows the company exists and is current, but owners and officers are usually evidenced by internal documents or a certificate of incumbency signed by an officer.
Do US formation documents need an apostille to be used in India or Europe?
Often, yes. India, the UK, France, Germany, the Netherlands and Singapore are parties to the Hague Apostille Convention, so a certified US state document is commonly apostilled by the issuing state. The UAE is not a party, so documents for UAE use go through embassy legalisation instead.
How recent does a registry extract need to be for a bank?
Each bank sets its own rule, but many ask for extracts or good standing certificates issued within the last three to six months. Order fresh copies close to the submission date rather than reusing formation-day copies.
Is the ACRA Business Profile enough to prove ownership of a Singapore company?
It usually lists shareholders and officers, which covers much of what a counterparty needs. Where a corporate shareholder is involved, recipients typically also want that shareholder's own documents to trace ultimate beneficial owners.
