Bridging the gap for effective asset transparency: Analysing land registers and beneficial ownership data for legal vehicles
Discussions and implications
This study has examined how different land registration models contribute to BOT of land, focusing on what information is collected, how interests and relationships are structured, and the extent to which data can be connected to related datasets, including BO registers for legal vehicles. Although the number of cases analysed is limited, the registers assessed reflect a wide range of institutional, legal, and technical design choices, allowing for comparison of two broad approaches to BOT of land.
Two approaches and their trade-offs
The analysis highlights the differences between land ownership registers and registers designed to collect BO information for land. Land ownership registers, exemplified by HMLR and the Estonian Land Register, focus legally defined relationships between land and immediate rightsholders. In these systems, transparency over BO depends primarily on the availability of reliable identifiers; the breadth of interests recorded; and the consistency of data structures that enable the connection of BO information to external related datasets.
Where these conditions are met, such registers can enable effective understanding of a broad range of interests in land without requiring asset registers to collect BO declarations themselves. Estonia illustrates how comprehensive coverage of registrable interests, combined with reliable identifiers for both natural and legal persons, can enable the understanding of BO networks by joining the data to basic and BO information for legal entities. By contrast, HMLR publishes information about a narrower subset of interests – limited to legal titles – but still enables the connection of information to BO and other company information through consistent use of company registration numbers.
In the second approach, the registers designed to collect BO information for land focus on identifying parties that hold indirect interests through the legal owner. Scotland’s RCI illustrates how requiring owners to declare their associates can improve visibility where a legal title alone does not reveal who can influence or control land. This includes person-to-person arrangements without the involvement of a legal vehicle, such as through contractual arrangements or informal influence. It also demonstrates how exemptions for land owners already subject to other transparency regimes also help reduce duplicate reporting. British Columbia’s LOTR adopts a more formalised version of this approach by requiring structured disclosure of interest holders through filings linked to land title applications, enabling systematic transparency over indirect interests in land held through legal vehicles. However, duplicate reporting with the forthcoming BO register for legal vehicles – based on different legal definitions, thresholds, and reporting timelines – limits the potential comparability of information and may increase reporting burdens.
Coverage of interests
Across the cases examined, the findings broadly support the central hypothesis of this study: effective BOT of land may not necessarily require asset registers to collect BO declarations. In jurisdictions where ownership information can be reliably joined with BO information for legal vehicles, BO registers of land do not necessarily provide a greater understanding of BO networks.
This conclusion is, however, contingent on the design characteristics of domestic and (access to) foreign BOT regimes. For example, LOTR applies a lower ownership threshold and different reporting timelines than the domestic BOT regime for legal vehicles, limiting comparability. At the same time, some land ownership registers collect information on a wider range of direct interests and rights attached to the land. Where such registers capture high-quality information on interest-holders and are supported by reliable identifiers and interoperable data structures, they may provide an understanding of a broader set of interests than registers that rely solely on BO declarations for land. For example, the latter may only collect information about interests held with the legal owner as intermediary.
Potential gaps that may remain when leveraging existing asset registers include: indirect ownership, benefit, or control interests exercised through legal owners who are individuals without the use of a legal vehicle; beneficial ownership through legal vehicles not subject to BO disclosure obligations, such as trusts in some jurisdictions; and beneficial ownership through foreign legal vehicles for which BO information is not available. BO registers of land, such as the RCI, cover these gaps. By contrast, these gaps remain in the Estonian Land Register, despite it capturing a wide array of rights and interests attached to land which can be reliably connected to shareholder, BO, and other information about domestic companies.
In principle, land registers could be extended to cover indirect interests where no legal vehicles are involved. However, their primary objective has often been to provide legal certainty over titles and other rights, rather than providing transparency over ultimate ownership, control, or benefit. To change this would require political will and legal reform to impose new reporting obligations on legal owners, which may fall outside the typical mandates of these registers. That said, such obligations may still be less burdensome than introducing new standalone BO declaration obligations for land, particularly where these would duplicate existing reporting requirements. User research is therefore needed to explore which interests and what level of detail are required to support different policy use cases.
Accuracy, scalability, and proportionality
An important advantage of leveraging existing asset registers lies in data accuracy and verifiability. Registered rights in land are typically subject to legal formalities, documentary evidence, and registrar oversight, meaning that information on direct rightsholders is, in principle, more reliable and easier to verify than self-declarations of indirect control relationships through BO reporting, even if comprehensive.
At the same time, while BO registers of land can enhance transparency within individual systems, the approach of strengthening and leveraging existing asset ownership registers – when supported by reliable identifiers and a comprehensive representation of interests – may offer a more scalable foundation for interoperability across asset classes and jurisdictions. This approach requires improved data-sharing across borders, particularly with respect to non-domestic interest-holders. In the UK, this challenge has been addressed by introducing new regulations requiring foreign corporate land owners to report their beneficial owners to Companies House, leveraging the institution’s existing role and capacity to collect, store, and manage BO data.
If international data-sharing continues to improve – especially where company registers collect and share information on shareholders and nominees alongside beneficial owners – this approach could support a more detailed and reliable understanding of BO networks. However, in contexts where such registers do not exist, are of limited quality, and where risks are particularly acute, imposing BO reporting obligations directly on asset owners may still have a positive impact in the short term.
Identifiers and interoperability
Across all cases examined, identifiers are confirmed as a critical enabler of interoperability. Systems that depend on reliable, widely used identifiers are significantly easier to connect to BO and other related datasets. Beyond identifiers, substantial variation also exists in how interest types and registered rights are defined and recorded. Land ownership registers that explicitly distinguish between a wide range of legally defined interests and systematically record information about each rightsholder offer greater analytical potential for understanding complex BO networks than systems with narrower or less explicit classifications. Although the sample examined is limited, the findings suggest that information on direct interests may offer greater scope for standardisation across jurisdictions and asset classes – and therefore semantic interoperability – than reliance on BO declarations submitted by asset owners. Given the sample size and the fact that all registers are in high-income countries, the sample is unlikely to be representative. The study did not assess whether land registers are sufficiently prevalent and of sufficient quality internationally.
The implications of these findings extend beyond land, and similar transparency challenges arise in other asset domains. For example, in the fisheries sector opaque ownership structures behind vessels and significant divergence in the collection and sharing of information by vessel registers enable sanctions evasion, shadow-fleet operations, and illegal, unreported, and unregulated (IUU) fishing. [41] In these contexts, unreliable identifiers and inconsistent definitions of ownership and control undermine effective enforcement and accountability. Recent discussions within regional fisheries management organisations, as well as at the 2025 UN Ocean Conference, reflect growing recognition of these risks. This comes alongside calls for clearer ownership definitions, improved data quality, and better cross-border information-sharing. [42]
From a policy perspective, the findings suggest that efforts to expand BOT to different asset classes may be better directed towards strengthening national information infrastructures before introducing new BO-reporting obligations. Investments in reliable identifiers, clearer definitions of interests, and interoperable data models can substantially increase the value of existing BO registers for legal vehicles, possibly without significantly increasing reporting burdens.
For global or regional initiatives considering consolidated BOT frameworks for assets, the most proportionate and sustainable approach is likely to build on interoperable national systems. This would enable datasets to be connected through shared semantics and identifiers rather than duplicating data collection. Over time, such systems could be reinforced through the selective integration of international identifiers, such as legal entity identifiers for legal vehicles, to support alignment with emerging international systems. [43] This approach offers greater scalability, reduces compliance costs, and provides a stronger foundation for cross-border analysis, verification, and enforcement.
Footnotes
[41] Tymon Kiepe and Peter Low, Using beneficial ownership information in fisheries governance (Open Ownership, 2024), https://www.openownership.org/en/publications/using-beneficial-ownership-information-in-fisheries-governance/; Anna Caprile and Gabija Leclerc, Russia’s ‘shadow fleet’: Bringing the threat to light (European Parliamentary Research Service, 2024), https://www.europarl.europa.eu/RegData/etudes/BRIE/2024/766242/EPRS_BRI(2024)766242_EN.pdf.
[42] Discussions in regional fisheries management organisations: Oceana, the Pew Charitable Trusts, and World Wide Fund for Nature (WWF), Call for the ICCAT to support stronger transparency and anti-IUU measures (Oceana, Pew, and WWF, 2025), https://www.iccat.int/DocsComm/uploads/PWG_429_ENG_20251105171132.pdf; 2025 OUN Ocean Conference: Environmental Justice Foundation, “Senior ministers pledge action against hidden owners of criminal vessels: press release”, 10 June 2025, https://ejfoundation.org/news-media/senior-ministers-pledge-action-against-hidden-owners-of-criminal-vessels-press-release; advocacy efforts: Oceana and Coalition for Fisheries Transparency, Beyond the Flag: Who Really Owns the World’s Large-Scale Fishing Fleet? (Oceana and Coalition for Fisheries Transparency, 2025), https://oceana.org/wp-content/uploads/sites/18/2025/05/Beyond-the-Flag-Policy-Brief_Oceana-CFT_reduced-size.pdf.
[43] Global Legal Entity Identifier Foundation, “Identifying Organizations – the Legal Entity Identifier (LEI)”, n.d., https://www.gleif.org/en/organizational-identity/introducing-the-legal-entity-identifier-lei; IMO, “IMO identification number schemes”, n.d., https://www.imo.org/en/ourwork/msas/pages/imo-identification-number-scheme.aspx.