Sufficiently detailed beneficial ownership information
Conclusion
A growing number of jurisdictions are planning for or implementing requirements for companies and other legal vehicles to disclose BO information. It is the responsibility of both policymakers and the registrar to ensure that there is sufficient detail in the information a BO register acquires to advance the jurisdiction’s policy aims. Declarations should generate high-quality and reliable information by collecting or retrieving at least the minimum amount of information needed for the registrar to perform its core functions, while considering additional fields that maximise usability for policy impact.
This requires several balancing acts. First, policymakers and registrars must balance the amount of information that is collected directly through BO declarations with what is retrieved from other sources in order to complete and verify a declaration. They must consider how to lower the burden of compliance without undermining the comprehensiveness of the information. Furthermore, ensuring a BO disclosure regime is legally robust requires balancing the level of detail with privacy frameworks, ensuring there is a robust and broad legal basis for requiring BO disclosure. Finally, the level of detail appropriate to the context must be balanced against the need for information to be interoperable, especially when collecting information on interests.
Given contextual differences in implementation, it is not possible to prescribe specific information fields that should be required as part of a BO declaration, nor how they should be gathered. Instead, this briefing has offered guidance on how to achieve a good level of balance across these areas. Regardless of the level of detail, BO information should be well structured to help understand relationships between individuals and legal vehicles, and to maximise its usability once shared within and outside of government.
Next page: Annex: Examples of information fields in beneficial ownership declaration forms