Sufficient detail

Last updated: July 2021

Beneficial ownership declarations should collect sufficient detail to allow users to understand and use the data

  • Information should be collected about:
    • the beneficial owner;
    • the declaring company; and
    • the means through which ownership or control is held.
  • Information should be collected in online forms with clear guidance that facilitates compliance.
  • Sufficient information should be collected to be able to unambiguously identify people, entities, and arrangements, using clear identifiers for natural persons, and legal entities and arrangements.
  • Information collected should be limited to what is necessary to achieve the policy objective.
  • Where BO is held indirectly through multiple legal entities or legal arrangements, or ownership or control are exerted formally or informally through another natural person, sufficient information should be collected to understand full ownership chains.
  • Absolute values, rather than ranges, should be used to define a beneficial owner’s ownership or control.
  • Data about any state ownership or control (domestic or foreign) should be collected in a standardised way.

Collecting key fields of data about the beneficial owner and the declaring company enables users to accurately interpret the data and determine which individuals and companies the declaration refers to. Collecting and publishing the means through which ownership or control is held further adds to the utility of the data by enabling users to understand how beneficial ownership is exercised. This should be done by collecting data through online forms with clear guidance.

Having clear identifiers – e.g. registration numbers for companies and taxpayer numbers for people – makes it easier to match declarations about the same people or companies and distinguish different people with the same name or similar details. This also allows users to link data with other datasets. Linking data transnationally is essential to realising its full potential to expose networks of illicit financial flows and support robust and efficient due diligence in the global economy. Being able to match and disambiguate is important; for instance, when entities emulate the names of respectable companies in order to obfuscate ownership in due diligence processes. The minimum amount of data to achieve this should be collected, but jurisdictions should limit collection to what is strictly necessary to achieve their policy aims, in order to limit privacy concerns.

Where ownership or control is held indirectly through multiple entities or through legal arrangements such as trusts, full visibility of ownership chains is important for understanding how ownership and control are exercised. Rather than ranges, collecting absolute values when disclosing the percentage of ownership or control will assist users in understanding how ownership or control is held. This is particularly important when ownership or control is held indirectly.

Although state ownership may not meet the definition of beneficial ownership, it represents a substantial amount of investment in large firms in strategic sectors. Therefore, governments should extend beneficial ownership disclosure requirements to explicitly require the disclosure of stakes held by the state, directly or indirectly, and distinguish state ownership from private ownership by collecting information in a consistent and defined format.