Sufficiently detailed beneficial ownership information
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Summary
To generate policy impact, registrars must collect sufficient detail in beneficial ownership (BO) declarations to identify individuals and legal vehicles and to understand the relationships between them. This briefing offers considerations for what information to gather through BO declarations, balancing comprehensiveness with data minimisation. Additionally, it provides guidance on developing robust legal frameworks and approaches to ensuring that BO registers are auditable, usable, and effective in supporting policy aims, such as tax enforcement, anti-corruption, and enhanced transparency.
Key Points
- Data gathering can be achieved by leveraging existing government sources to pre-populate digital forms and complete declarations, as well as through direct collection from legal vehicles’ designated representatives when necessary.
- A robust legal framework is essential, with legislation clearly outlining who must submit what information, when, and to which authority.
- Privacy and data protection considerations should guide the BO declaration process, ensuring that only the minimum necessary information is collected.
- The use of reliable identifiers – such as passport numbers, tax identification documents, and legal entity identifiers – is crucial for effective identity verification and to allow users to make connections across datasets.
- Various models for capturing information on BO interests (e.g. full network disclosure, relevant legal entities, direct-interest declarations, and aggregated direct interests) can be used to capture ownership and control relationships and understand networks.
- Ensuring BO data is auditable and usable requires maintaining an up-to-date record of changes over time, and it may involve tracking who has accessed the data.
- Ongoing stakeholder engagement and user research are critical for refining a BO registrar’s approach to implementation and remaining effective and aligned with evolving user needs.
