The steps that Argentina has taken on the requirement to report BO data are not insignificant. They are, however, the result of the isolated actions of certain national government agencies with partial competency as well as the resources to move forward, though only up to a certain point. It is precisely at this point that the next step must be taken so that disclosure of beneficial owners can become a public policy borne out over time. To achieve this, of course, the work undertaken thus far must continue.
Not only must there be a law to establish a central BO register, but as a preliminary step it would be appropriate to foster conditions so that such a law can be implemented as soon as it passes. Accordingly, it is indispensable to strengthen coordination among the relevant actors, in particular, through consistent and sustained actions over time, first within the Executive Branch of government, and subsequently in the provinces, making use of the agenda in place in the extractive sectors.
EITI is a response to the demand for greater transparency and accountability that the extractive industries have in comparison with other sectors. Nevertheless, national governments are also included in the standard and are supposed to ensure compliance and adherence on the part of companies in the sector.
Up until now, it has not been possible to confirm significant progress with regard to Requirement 2.5 of the EITI Standard. The report on Scope, Materiality and Systematic Disclosure  issued in 2020 states that there was no information available to assess the matter, and recommended an analysis of certain modifications bearing on the promotional regimes in force in order to acquire the necessary information. So far, such action has not been taken.
The Progress Report for 2021 states that the purpose of adhering to the Opening Extractives programme was to develop guidelines and a work plan to be implemented with public agencies and the industry.
The context in which the Road Map will be developed to comply with the standard is timely, and, in spite of the shortcomings noted, we understand that the political and administrative will does exist to move forward to comply fully with Requirement 2.5.
The mining and hydrocarbon authorities have the functional and administrative competencies to collect BO data from companies in the sector through the recommended pilot trial via registration of the companies in promotional regimes, by inserting fields specifically for BO.
However, this would only be a pilot trial, for beta-testing fields, requirements, real possibilities for implementation, etc. Furthermore, the Secretary of Mining and the Under Secretary of Hydrocarbons should have technical assistance and support to strengthen their role as the country’s coordinators and drivers in this matter.
On the other hand, the role of civil society organisations is essential to bring about a dissemination of the initiatives, and their activities are also subject to the rule of transparency that applies to other actors.
The final goal is an ambitious one, and requires an ongoing and iterative institutional commitment, for which numerous actors will be needed to achieve a basic convergence that can supersede impediments.
The gradual integration of the provinces into EITI is indispensable. Because of this, to carry forward the pilot trial, it might be possible to begin in those provinces in whose territories companies that are already EITI participants operate, especially companies that have developed the most along these lines.
At the same time, it is indispensable to create working situations where high technical capacities, operational tools and participants with some degree of autonomy can interact so they can select for themselves the best options for addressing implementation issues.
The challenge is not an insignificant one, yet moving forward in a preliminary arrangement with the extractive sectors – that have already expressed their intentions by adhering to EITI, albeit with the nuances we have glimpsed throughout this study – is one possible option for taking definite steps towards the ultimate goal.
 Santiago J. Dondo, Mariana Palacio, and Juan Cruz Vieyra, “Report on Scope, Materiality and Systematic Disclosure,” BID and EITI Argentina, June 2020, 54, https://www.argentina.gob.ar/sites/default/files/informe_de_alcance_materialidad_y_divulgacion_sistematica_0.pdf.