bank wants to see an organizational chart of our holding and subsidiaries

Group structure is part of client due diligence, not risk assessment

The bank usually requests the organizational chart as part of client due diligence: it needs to know who is behind the business, who the ultimate beneficial owners are, and how control flows within the group. This is not a question about sustainability or cybersecurity, and not a credit assessment of the business itself — it concerns the origin of funds and control. A holding with multiple subsidiaries, a joint venture, or shareholders in another country make the structure less straightforward for the bank than a simple private limited company, and then the bank wants to see the diagram in black and white rather than reconstructing it from separate answers.

Often the same question is also implicitly asked through separate fields: in which countries does the company have operations and under what registration number is the company registered. An organizational chart answers those questions in one picture: it shows the parent company, the subsidiaries, and the percentages or voting rights between them. If you don't have a current diagram, an extract from the Business Register with the corresponding Chamber of Commerce registration numbers of each group entity is often a workable interim solution, although that does not always replace the complete overview the bank is asking for — that depends on the bank.

Derivable from the Business Register Act, not from a sustainability framework

This question is separate from the CSRD, the VSME standard or NIS2: these frameworks concern reporting and security, not ownership and control within a group. The basis for the organizational chart lies in the data recorded for each business according to the Business Register Act 2007 — from this it is possible to determine which entities exist, who the managers are and how they are legally connected to each other. For drawing up a diagram, that register is usually the best starting point, even though it does not provide a ready-made organizational chart.