From disclosure to decision-making: How pioneer regulators are laying the groundwork for using beneficial ownership data in extractive licensing

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Beneficial ownership transparency (BOT) has become a mainstream policy expectation of good natural resource governance, and resource-rich countries have been among the earliest movers to implement it. By shedding light on who owns, controls and benefits from companies operating in the extractive industries (that is, their beneficial owners), BOT aims to ensure these individuals are visible, including to the sector’s regulators. This transparency is especially important in the highly strategic extractive sector, which generates consequential revenues. This can create local business opportunities, drive foreign direct investment and reap major domestic economic benefits – when not hindered by corrupt practices and attempting to bypass laws and regulations.

Publishing beneficial ownership (BO) information has been a requirement in the Extractive Industries Transparency Initiative (EITI) Standard since 2020, but sharing this information is only the starting point. The value of BO information is realised when people and agencies use the data to make informed decisions and ensure effective oversight. Licensing and contracting – where extractive rights are granted and renewed, and where the terms for extractive projects are defined – is a foundational stage in the extractive value chain, and therefore one of the most strategic entry points for using BO data. Decisions taken here shape who benefits from a country’s natural resources, in some cases for decades.

Jointly implemented by the EITI and Open Ownership, the Opening Extractives (OE) programme has been partnering with resource-rich countries to move BOT from disclosure into practical use. Among the agencies the programme works with, two have pioneered progress on BO data use in licensing: the Ministry of Territorial Administration and Infrastructure (MTAI) in Armenia, regulating mining and subsoil activities; and the Petroleum Commission (PC) of Ghana, regulating upstream petroleum. Both have engaged with OE to explore how BO data can support their mandates, as well as testing a new manual on the use of BO data in extractive licensing and contracting. Their progress carries lessons for regulators worldwide.

Grounding beneficial ownership data use in policy priorities

With the OE programme team, both MTAI and the PC have explored where BO information can help their agency effectively fulfil its objectives.

Ghana

For the PC, engagements highlighted a priority to protect the investment climate and support opportunities for Ghanaian companies by enforcing local content and local participation regulations, which require differentiated treatment for fully-indigenous, indigenous, and foreign companies. Identifying the beneficial owners of companies applying for a permit can help regulators see instances where a company presents itself as Ghanaian while being ultimately owned or controlled by foreign interests. This practice – known as “fronting” – is classified as an offense in Petroleum (Local Content and Local Participation) Regulations, 2013 (L.I. 2204). This issue also has direct fiscal implications, since permit fees differ across company categories, with Ghanaian companies paying lower fees than foreign companies.

“Ghana is known for being open for business. To maintain this, predictability is important. Investors want a stable place where they can deploy their capital. When we do BO screening and proper due diligence, we are able to both confirm that a company has the technical competence and ethical standards required, and find out who is behind this company. Our citizens should also know that regulators are not skipping any steps in this process because public trust is a key foundation and it also gives us a social license to operate.” – Grace Kumah-Madjie, Senior Permitting Officer and Legal Counsel at PC explained at the OE panel at the OECD Global Forum 2026

OE panel at the OECD Global Forum 2026

Armenia

For MTAI, engagement with the OE programme surfaced entry points for the use of BO information: monitoring ownership concentration and supporting the government’s 2023–2035 strategy for the mining sector, which prioritises transparency and investor confidence.

“Mining generates high revenues. In light of democratic developments in the world and in Armenia, to have economic growth and maintain investments in the country, the public needs trust and transparency, which BOT helps bring. People should know how resources that belong to them are managed.” – Armenuhi Mayilyan, Chief Specialist of the Geological Expertise Division of the Subsoil Department of the MTAI

The government strategy also calls for responsible resource use, including by tackling the environmental and social risks that come with mining activities. BO data can help regulators check that the people who own or control an applicant company have not themselves broken any laws or regulations, and that they do not own other non-compliant companies. In both cases, BO data adds valuable new information that can support the agencies to achieve their policy goals.

Testing guidance, contextualising practice

Recognising that using BO information within licensing is new to many countries, the OE programme worked with these and other licensing agencies to develop a manual, offering four practical steps for screening applications using BO information and considering impacts on decisions. Over the past year, MTAI and the PC have been among the first agencies to test the beta version, which is now being expanded and refined for global publication in October 2026, alongside the EITI Global Conference.

This work has served two purposes: to give the agencies structured guidance to think through how to situate BO data reviews in relation to their existing due diligence work; and to generate direct feedback on where the manual worked well, and where it needed refinement for different country contexts. Kristina Gevorgyan, Chief Specialist of the Subsoil Use Rights Formation Division of the Subsoil Department of the MTAI noted that “the manual is an innovation, as it provides very concrete tips on how to process from the beginning”. Likewise, Armenuhi Mayilyan, Chief Specialist of the Geological Expertise Division of the Subsoil Department, observed that as part of seeking to achieve results in such a new and complex area, “the manual is very helpful in guiding us in our steps along the way”.

Creating the right conditions for beneficial ownership data use

The OE programme’s work with these agencies highlights key pre-conditions that need to be in place in order to unlock the power of ownership data in extractive licensing.

Legal mandate: Armenia is a civil law country, and as such, MTAI cannot use BO information as a basis for licensing decisions without an explicit legal mandate. Engagements with the Ministry of Justice on possible amendments to the Subsoil Code are ongoing. In Ghana, a common law country, the PC has voluntarily elected to collect BO information as part of permit applications in alignment with the EITI Standard requirement 2.5, and is now exploring decision-making pathways for BO-related red flags. However, engagements highlighted that increased prosecutorial power for regulators would facilitate BO data use, especially to tackle potential conflicts of interest.

Access to usable BO data: Armenia’s free-to-access, public BO register removes a friction that persists in Ghana, where the Office of the Registrar of Companies applies a per-search fee – a practical constraint when the PC processes 50 or more permit applications and renewals every month. The data that is accessed also needs to be usable – that is, easy enough to access, interpret, connect and rely on – so that regulators can use it as needed. An example of a valued feature of Armenia’s BO register is access to historical BO records. This allows easily identifying red flags such as a change in declared beneficial ownership that occurs immediately before or after applying for a license, which may be a sign of a company seeking to conceal true ownership.

Digitisation and interoperability: BO data does not get used in isolation, but is rather cross-checked with other types of information to better understand relationships between individuals and companies. Armenia’s 2023–2026 Anti-Corruption Strategy commits to interoperability between the State Register and other databases. MTAI is digitising its own records – geology, fossil, mining resources, contracts and suspended companies. Digitising and increasing the interconnection between various datasets can help provide a full view of information about a sector and facilitate efficient due diligence. In Ghana, the existence of digital systems such as the Office of the Registrar of Companies’ BO register and the PC’s e-portal could facilitate such interconnection. While regulators who engaged with the OE manual highly valued tips on where to find information relating to companies with a footprint in other countries, tracing cross-border corporate networks and accessing BO data held elsewhere is still a significant challenge for many BO data users. Open Ownership and its partners continue to explore emerging solutions to advance policy thinking on this matter (for example, see 2026 report Connecting ownership data: Practical pathways to tackle cross-border financial crime).

Institutional leadership and foundational training: Both MTAI and the PC invested in building staff understanding of BOT concepts, which is crucial to developing the knowledge and confidence needed across teams to identify where BO data fits and how it can be leveraged within their work. Building staff confidence and support also involves putting clear processes in place for what constitutes a red flag and providing clarity on what staff members should do when such flags are identified. Practical and procedural capacity, together with a shared sense among staff and leadership of how these measures will contribute to wider strategic objectives, enable processes on paper to operate in practice.

Inter-agency collaboration: It is also important to identify who can support regulators’ work and to define collaboration pathways. For example, in Armenia, the Corruption Prevention Commission (CPC) was involved in OE engagements with MTAI, given its key role in tackling conflicts of interest. Broader OE engagements also pointed to the role of third-parties such as civil society organisations (CSOs), journalists and local communities who can share valuable investigations and insights into company ownership. This is illustrated by the case of a Ghanaian CSO which found criminal links with a mining company and raised it with authorities, leading to the suspension of the company’s extractive rights.

What comes next

Both MTAI and the PC continue to explore how to use BO information systematically in licensing decisions. In Armenia, that means securing a legal amendment to expand MTAI’s mandate to do so, updating internal guidelines and building staff capacity. In Ghana, it most likely means resolving access barriers, exploring further prosecutorial powers for extractive regulators, and identifying institutional ways to set up clear pathways for what happens when any BO-related risks are identified.

The practical hurdles and emerging advice for creating the right conditions for BO data use in licensing are all aspects that many regulators moving from policy to practice will face. This is why both agencies’ openness to sharing their BOT journeys has been so valuable. Lessons from Armenia and Ghana are being fed back into the next iteration of the OE manual, due for publication in October 2026, which will provide a valuable new source of information to guide regulators in extractives and beyond.