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Sufficiently detailed beneficial ownership information

Contents

Overview

The requirement to disclose beneficial ownership (BO) information ensures that the natural persons who ultimately own, control, and benefit from companies and other legal vehicles – that is, the beneficial owners – are clearly identified. It also clarifies the nature of the relationships between beneficial owners and legal vehicles, making it possible to understand BO networks, or the relationships between individuals, legal vehicles, and assets.

BO information can be used for purposes such as making decisions about who benefits from natural resource extraction and public procurement; detecting and preventing corruption; safeguarding national security; and improving taxation; among other aims. [1] It is the responsibility of both policymakers and the agency administering the register (hereafter, “the registrar”) to ensure the BO information it acquires is sufficiently detailed to be able to be used to advance a jurisdiction’s policy aims.

This policy briefing focuses on the need for a sufficient level of detail in the BO information that is gathered, processed, and stored by agencies administering BO registers. It emphasises the importance of registrars balancing comprehensive data collection that enables policy impact with privacy, while leveraging existing government information sources for ease of compliance and verification. By outlining core objectives for registrars, the briefing provides guidance on how to establish robust BO disclosure regimes.

BO declarations are sufficiently detailed when they enable the registrar to achieve three objectives:

  1. identify individuals and legal vehicles,
  2. understand the relationships between them, and
  3. ensure the data is auditable and usable.

BO registers should facilitate transparency and accountability, and the use of BO information by users outside of the registrar should advance policy aims such as taxation, anti-corruption, and natural resource governance.

This briefing offers guidance and considerations focusing on three main areas which can shape the ultimate effectiveness and impact of beneficial ownership transparency (BOT) reforms.

First, registrars can gather detailed information by retrieving it from existing sources, directly collecting it from individuals, or a combination of both. To determine the best approach, registrars should conduct data and systems-mapping as well as user research with stakeholders.

Retrieving information from existing sources

  • Where possible, registrars should consider retrieving information from outside the BO register to pre-populate or verify BO declarations.
  • Pre-populating digital forms with information from other government sources can reduce redundancy and errors, raising the level of users’ confidence in the register’s accuracy.
  • Data retrieval can be useful to source verified information, or to cross-check information that is collected directly through declaration forms as a means of verification, but in order to do this effectively considerations must be made on the accessibility and accuracy of existing data sources.

Directly collecting information

  • Certain information will have to be collected directly by the registrar when it cannot be reliably retrieved from another source.
  • Supporting documentation may also be required in order to verify certain BO information, especially for ownership and control interests as well as for non-residents.
  • Digital webforms are the preferred means to collect information because they allow for pre-populated fields and better onward handling of structured information, but using other formats like paper or PDF may be necessary depending on the jurisdiction’s digital infrastructure.

Second, a robust BO disclosure regime requires a legal basis for registrars to collect, process, and share information, as well as obligations for reporting legal vehicles to disclose BO information. A broader legal basis may allow for a wider range of use cases.

  • Legislation should be written in line with domestic privacy and data protection frameworks, adhering to the principle of data minimisation by registering and sharing only the minimum information necessary.
  • It should specify who must submit what information, when, and to which authority, and it should empower the amendment of information requirements through secondary legislation for adaptability.
  • The focus should be on defining what kind of information should be gathered, keeping in mind the needs of users, rather than specifying the particular design of a form used to collect the information.

Third, determining how to best achieve the registrar’s three main objectives for processing BO information in a given context is the primary consideration for choosing which information fields should be collected or retrieved, then stored, as part of a BO declaration.

Verifying the identities of individuals and legal vehicles

  • Identification attributes, including reliable identifiers such as passport numbers and tax IDs, are crucial for effective identity verification of natural persons. Some jurisdictions also assign unique identifiers for use within the BO register.
  • Company registrars play the largest role in identifying companies by assigning reliable identifiers and reviewing supporting documents, and they maintain information about the individuals operating those companies.
  • Reliable identifiers for legal vehicles should be unique, persistent, and resolvable. When possible, the same identifiers should be used across BO and other government registers to facilitate verification and data integration.

Understanding relationships between individuals and legal vehicles

  • BOT aims to capture both direct and indirect relationships within BO networks, requiring detailed information about the interests that establish these links. For direct interests, information is needed on the type of interest as well as the means of ownership or control, the level of interest, and when the relationship begins and ends.
  • There are different approaches to collecting sufficient detail in order to understand indirect interests and full BO networks, and four example approaches covered in this briefing include: full network disclosure; relevant legal entities; declaring beneficial owners and direct-interest holders; and aggregating direct interests.
  • Registrars must balance the level of information collected on interests, ensuring there is sufficient detail for verification and use while considering interoperability with other jurisdictions.

Ensuring BO information is auditable and usable

  • Policy impact from BOT reforms depends on actors using information on BO to answer their questions and reach actionable insights.
  • Many users of BO information have overlapping needs, including making connections between entities, ensuring accuracy, and having access to high-quality, structured data that is regularly updated. These needs are largely met through the first two objectives.
  • Registrars should also capture details about changes over time and user access, the person making a declaration, and any specific attributes relevant to the policy aim.

The level of detail of BO information is a core tenet of Open Ownership’s Principles for effective beneficial ownership disclosure. The Principles are a framework for considering the elements that influence whether reforms will lead to high-quality and reliable data, maximising usability. The recommendations in this briefing should be considered alongside other elements that influence the effectiveness of BOT reforms, as detailed in other Open Ownership policy briefings and technical guidance. [2]

The briefing first explores approaches to gathering information on beneficial ownership, considering the balance between collecting information directly and retrieving it from existing sources. It then looks at how to develop robust legislation that aligns with privacy and data protection considerations. Since it focuses mainly on gathering rather than sharing information, the question of what kinds of information end-users should be able to access carries a separate set of considerations and is not covered in this briefing. The final section offers guidance on how a registrar can achieve its objectives and fulfill its role of catalysing data use for policy impact.

Figure 1. Summary of a beneficial ownership disclosure process resulting in sufficiently detailed information

01 Disclosure Process

Figure 1 visually represents how, underpinned by a robust legal framework, a system of BO disclosure can ensure there is a sufficient level of detail in the information that is gathered, processed, stored, and made available to be shared with data users. Examples of guiding questions that registrars can ask as they design and improve each stage include:

Gather

  • Are we gathering information such that it can be stored and shared as structured data?
  • Do we know what information sources we could draw on in our agency or other agencies to complete or verify BO declarations?
  • Have we consulted users of the declaration form and minimised the compliance burden?

Process and store

  • Can we identify beneficial owners and legal vehicles at a high level of confidence?
  • Can the relationships in BO networks and changes over time be understood clearly?
  • Can we identify and contact the party submitting each BO declaration if necessary?

Share

  • Have we asked end-users of BO information what information fields they will need?
  • Will users easily be able to connect BO information with other datasets?
  • Can we safely track who has used the information we hold?
Footnotes

[1] Tymon Kiepe and Peter Low, Using beneficial ownership information in fisheries governance (Open Ownership, 2024), https://www.openownership.org/en/publications/using-beneficial-ownership-information-in-fisheries-governance/; Julie Rialet and Alanna Markle, Lessons for an accountable transition: Leveraging beneficial ownership information for natural resource governance (Extractive Industries Transparency Initiative (EITI) and Open Ownership, 2024), https://www.openownership.org/en/publications/lessons-for-an-accountable-transition-leveraging-beneficial-ownership-information-for-natural-resource-governance/; Tymon Kiepe and Eva Okunbor, Beneficial ownership data in procurement (Open Ownership, 2021), https://www.openownership.org/en/publications/beneficial-ownership-data-in-procurement/; Alanna Markle and Tymon Kiepe, Who benefits? How company ownership data is used to detect and prevent corruption (EITI and Open Ownership, 2022), https://www.openownership.org/en/publications/who-benefits-how-company-ownership-data-is-used-to-detect-and-prevent-corruption/; Tymon Kiepe, Using beneficial ownership data for national security (Open Ownership, 2021), https://www.openownership.org/en/publications/using-beneficial-ownership-data-for-national-security/; Tymon Kiepe, Leveraging ownership information to improve taxation (Open Ownership, 2025), https://www.openownership.org/en/publications/leveraging-ownership-information-to-improve-taxation/.

[2] The Open Ownership Principles and their supporting materials can be found here: Open Ownership, Principles for effective beneficial ownership disclosure (Open Ownership, updated 2023), https://www.openownership.org/en/principles/.

Next page: Gathering detailed information