Comprehensive coverage

Last updated: July 2021

Data should comprehensively cover all relevant types of legal entities and natural persons

  • All types of entities and arrangements through which ownership and control can be exercised – including, for example, state-owned enterprises (SOEs) and publicly listed companies (PLCs) – and all types of beneficial owners (including non-residents) should be included in declarations, unless reasonably exempt. (see below).
  • Any exemptions from full declaration requirements should be clearly defined and justified, and reassessed on an ongoing basis.
  • Exemptions from declaring beneficial owners should be granted only when the entity is already disclosing its beneficial ownership in sufficient and accessible detail, and this information is accessible to authorities through alternative mechanisms with equivalent requirements (e.g. for PLCs listed on exchanges with equivalent disclosure requirements).
  • Entities exempt from declaring their beneficial owners should not be exempt from all disclosure requirements and should declare the basis for their exemption.
  • All exemptions from declaration should be interpreted narrowly.

Comprehensive coverage of different entity types is important because if certain types of legal entities are not covered, potential loopholes form that can be exploited for illegitimate purposes. Similarly, the disclosure requirements should cover all categories of natural persons (for example, domestic and foreign citizens who meet the definition of beneficial owner) to avoid creating a loophole that could be exploited in order to avoid disclosing ownership.

Disclosure regimes should take the inclusion of all types of entities and categories of people as a starting point, and subsequently assess which entities and people can be excluded (for instance, where an entity is already disclosing beneficial ownership through a mechanism with equivalent requirements); these assessments and justifications should be made public. In all cases, exemptions should be narrowly interpreted.