Beneficial ownership declaration forms: Guide for regulators and designers

Open Ownership's example declaration form

OO’s example disclosure form was made to demonstrate good practice in form design for collecting structured BO data in line with the Open Ownership Principles (OO Principles). Designing a form at the individual country level involves clarifying specific needs and identifying the appropriate information and design to meet them. OO’s example form provides a useful reference point for local form development, but its elements will always need tailoring to fit the requirements, legal environment and policy choices of each jurisdiction.

The example form is presented as a spreadsheet, since these are relatively easy to share, edit, and comment on. This also lends clarity to the structure of the main form and subforms, and to the navigation between them. In most jurisdictions, a final BO declaration form would be produced as a webform.

A spreadsheet can be used as an outline or prototype on which to base the production of a webform. However in some cases, factors like the number of company declarations or the level of digitisation of related systems might make paper or spreadsheet forms a more feasible option. These will make onward data management and handling more challenging. In all cases, a custom form, designed and tested with domestic firms, in an appropriate format, will ultimately be best suited for local use.

With this in mind, the example form may be used in various ways:

1. As a reference point when drafting regulations. For example, when considering BO declarations from publicly listed companies (PLCs), regulators might refer to the form to see what information the example form has collected about them.
2. As a reference point during form design. When developing a BO collection form from a blank page, it may be helpful to refer to the example form when questions come up. For instance: what should be done if a declaring company cannot retrieve the identity of a beneficial owner?
3. As a starting point for form design. Reviewing the example form alongside regulatory requirements might indicate that – with amendments – it could collect the information needed. In this case, regulators and form designers can edit, comment on, and share the form with a view to developing a customised, testable prototype form.

The example form is aligned with the Beneficial Ownership Data Standard (BODS). BODS is a useful reference point when addressing regulatory and form design questions about how to collect good quality BO data.

Note that any final BO declaration form should complement existing information about companies, such as that in a company register, rather than duplicate it.

Next page: Aligning forms with the company register (or other company-centred database)