Kewal Krishan & Co, Chartered Accountants
Substantial Control Cash Accounting

Unlocking the Puzzle of Substantial Control: Who’s in Charge?

Ever wondered who’s really in the driver’s seat when it comes to reporting companies? Well, it’s time to unravel the mystery because understanding substantial control is your key to navigating the complex world of compliance!

The Power of Identification

Reporting companies, listen up! It’s your duty to identify all individuals who wield substantial control over your ship. And guess what? There’s no limit to how many individuals can be on that list. It’s all about transparency and accountability.

Four Criteria, Countless Possibilities

So, what defines substantial control? Brace yourself, because there are four general criteria:

1. Senior Officer: If you’re in a high-ranking position like a president, chief financial officer, or CEO, congratulations—you’re on the list!

2. Authority to Appoint or Remove: If you have the power to hire or fire key officers or a majority of directors, you’re in the driver’s seat.

3. The Decision-Maker: Maybe you’re the one calling the shots, making crucial decisions that steer the company’s course.

4. Other Forms of Control: It’s not just titles that matter. Any other form of substantial control also puts you on the radar.

See the Chart for Clarity

Confused? Don’t worry! We’ve got a handy chart that breaks down these criteria in detail. It’s your roadmap to understanding who falls under the substantial control umbrella.


Understanding substantial control is essential for compliance in today’s regulatory environment. It’s about recognizing who has the power within a company to make significant decisions or influence operations. This clarity ensures transparency and accountability, crucial for both reporting companies and regulatory bodies.

Have Questions?

Don’t let the maze of Beneficial Ownership Information reporting overwhelm you. Reach out to our team for expert guidance and support tailored to your business needs. Contact our COO Anshul Goyal at and schedule a consultation today to navigate the compliance waters with confidence.


This content is for informational purposes only and should not be construed as legal, tax, or financial advice. The definitions and regulations discussed are subject to change, and the applicability of the Beneficial Ownership Information Reporting Rule may vary depending on specific circumstances. Always consult with a qualified professional to understand how these regulations apply to your particular situation.

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