For the past six months, Open Ownership and our technical partners at Open Data Services have been working to understand more about France’s national beneficial ownership data.
This work advances Open Ownership’s strategic goals to ensure more and higher-quality beneficial ownership data is available to stakeholders in governments, companies, and civil society. It also enables our team to learn from real-world beneficial ownership data and refine our recommendations to countries implementing reforms.
If successful, we would have republished it via our data analysis tools for anyone to reuse as well as combining it with other European data sources and making it searchable via the Open Ownership Register.
Unfortunately we have not been successful due to issues with accessing the data through the INPI application programming interface (API), as well as issues we discovered within the data itself.
INPI’s new API was released in January 2023 to publish beneficial ownership and other information. The API is commendable and is in line with international best practice. However, its implementation has had a challenging start, and our initial analysis was hampered by certain functionality not working on release; several of these issues have however since been fixed.
Following the November 2022 Court of Justice of the European Union (CJEU) judgment on public beneficial ownership registers, the beneficial ownership data was removed from the API. It was subsequently reinstated, but documentation hasn’t kept up with the changes made.
We welcome France’s decision to keep its beneficial ownership data public and available to developers, pending a stakeholder consultation. However, with the hope of encouraging collaborative improvements to the register and making it easier for people to use the data, we want to share some of the access and data quality issues we experienced.
Access issues experienced by our analysts include:
- various bugs on the differential API rendering it unusable, in particular the pagination functionality;
- and a daily quota of 10,000 calls to the API limiting the speed of access.
Data quality issues include:
- apparent duplication of beneficial owners (up to 12 entries for one individual in one sample);
- no start or end dates for interests;
- data being present via the website search that is not reflected in the JSON;
- and vice versa with beneficial ownership data being present in the JSON but not via website search.
These and other issues uncovered during our detailed investigation are not unique to our team’s attempts to interrogate the data. Entries on discussion forums show that others are experiencing the same problems, and we have spoken to a number of data users to check our findings.
Issues like the above are not unusual when a new API service launches, and it is through people using the data that issues can be identified and then resolved. So far we have not been able to get in touch with the technical team in charge of the new API. We would be happy to discuss our experience and recommendations with the team.
In making beneficial ownership data available via an API, France has opted for a powerful tool that can enable users to make the most of its beneficial ownership data in preventing money-laundering and corruption. However, to realise its full impact, experience from other countries shows that the INPI team should engage with users of the data to identify and resolve technical and data quality issues.
We stand ready to collaborate with INPI in doing so and urge their teams to engage more with users to increase the utility of its data and to enhance its impact.
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