Beneficial ownership declaration forms: Guide for regulators and designers
Aligning forms with administrative systems
In the example form, the generic “Office use only” sheet can:
- prompt consideration of the administration of the BO declaration process, amongst regulators; and
- make the links to company-related systems that are already in use.
In particular, there are three sections:
- administrative tracking;
- data review and verification;
- publication information.
The administrative tracking section gives the ability to follow and track the issuing of the form and its return. In cases where an agency issues the form to companies to complete (for example where it is downloaded by a company with certain information automatically populated), most fields in this section would be completed prior to the declaration form being issued to the company for completion. Each declaration could be given a unique company filing ID. If a company has completed a declaration in the past, the prior company filing ID should also be noted. This allows changes over time to be visible.
There are also fields in this section to link the company filing to records in other systems (“External references”). Linking to records about the company and its activities in other systems will enable administrators and users to connect information. As an example, the existence of a government procurement system has been assumed on the form. The name of the government project plus a bid ID can be recorded, and there are placeholders for second and third systems.
Finally, it is in this administrative tracking section that one would note whether the declaring company is part of a joint venture. (For example, by issuing a shared “joint venture ID” for partners in a joint venture.)
The data review and verification section would be completed after the declaration has been returned. Again, there are placeholders for particular questions or links to external verification systems and reports. For more information on good practice in verification of BO data, see OO’s Verification of Beneficial Ownership Data policy briefing.
The publication information section is where the name of the authority publishing the declarations should be recorded, along with the licence under which the data was published. Publishers are encouraged to use a Public Domain Dedication or Open Definition Conformant licence.