Bridging the gap for effective asset transparency: Analysing land registers and beneficial ownership data for legal vehicles
Research question and scope
The central hypothesis of this research is that connecting existing land ownership registers with existing BO registers for legal vehicles can provide a more scalable and proportionate foundation than creating new standalone BO registers for land, provided they are supported by:
- strong and consistent identifiers for land, legal entities, and people;
- comprehensive and well-structured representations of rights and interests, including those that do not derive from direct legal ownership; and
- access to BO information for legal vehicles, including non-domestic legal vehicles that own land.
These conditions reflect widely recognised principles for effective register design, including clarity of purpose; consistent and unambiguous data structures; and the use of reliable identifiers. [10] Where they are satisfied, asset registers may not need to collect new BO declarations directly. Instead, they can focus on capturing high-quality information on direct interests, alongside identifiers and data structures that enable reliable linkage to existing BO and related datasets.
Achieving this outcome requires a degree of semantic interoperability, such that key concepts, relationships, and identifiers are defined consistently enough for land registers, BO datasets, and other systems to be connected and jointly interpreted. [11] However, an important limitation remains even within a semantically interoperable framework: if certain rights or interests – such as delegated control, usufructs, mortgages, or other use of benefit rights – are not recorded, significant relationships may remain hidden, creating opportunities for opacity or the use of nominee arrangements.
This tension motivated the following research question of this study:
Under what conditions – in terms of collection, structuring, and connection of information – can existing land ownership registers be leveraged to provide a sufficiently detailed understanding of BO networks involving land, and how does this compare to the way things are currently?
To address this question, the analysis compares land registers reflecting the two main approaches identified above and assesses them against the minimum set of information necessary for interoperability and effective linkage with BO data. The assessment focuses on the following:
- Data model: schema objects, relationship structures, and completeness of data fields.
- Identifiers: availability and reliability of identifiers for land, legal entities, and people.
- Interest types: interests captured (e.g. ownership, leases, mortgages, servitudes); ownership forms (e.g. sole/joint ownership, marital property); and temporal and quantitative attributes (such as start and end dates, and ownership shares or percentages).
- System integration: strengths and limitations affecting the ability to link land data with BO and other relevant datasets, and the extent to which this supports a comprehensive understanding of ownership and control networks.
Together, this framework: enables a comparative assessment of land registers in practice; supports the evaluation of their suitability within interoperable BOT ecosystems; and helps identify proportionate and scalable improvements for linking land and BO information.
This analysis is not intended to be exhaustive. It focuses on a limited number of land registers, selected because they are sufficiently documented, accessible, and feasible to analyse in practice. The assessment draws on legal frameworks, technical guidance, and available data, but does not comprehensively evaluate the BO regimes for legal vehicles in each jurisdiction, nor the prevalence and quality of land registers globally. Importantly, the study does not attempt to reconstruct or analyse complete BO networks. Instead, it evaluates whether existing land registers collect sufficiently detailed and appropriately structured information such that, when linked to datasets of BO of legal vehicles, they would enable meaningful visibility over direct and indirect interests in land.
The final selection therefore represents a varied yet manageable set of land registers for assessment (Table 1).
Table 1. Overview of selected land registers
| Register | Responsible agency | Geographic coverage | Access level and cost | Data format and delivery | Update frequency |
|---|---|---|---|---|---|
| HMLR [12] | HMLR, UK Government | England and Wales, UK | Public access; free of charge to search; account registration and licence agreement required | CSV bulk download; application programming interface (API) (JSON format) | Monthly |
| Estonian Land Register (Kinnistusraamat) [13] | Centre of Registers and Information Systems (RIK) | Estonia | Restricted access; paid individual queries; bulk/XML access available under contractual agreement | Online web portal; XML service (contractual access) | Continuous/rolling updates |
| RCI [14] | Registers of Scotland (RoS) | Scotland, UK | Public access; free of charge to search | Online web portal; no public bulk download or API | Continuous/rolling updates |
| LOTR [15] | Land Title and Survey Authority of British Columbia (LTSA) | British Columbia, Canada | Public access via myLTSA Explorer; free of charge to search | Online web portal; no public bulk download or API | Continuous/rolling updates |
Footnotes
[10] David Miller, Sym Roe, and Leigh Dodds, Registers and collaboration: making lists we can trust (Democracy Club, 2018), https://democracyclub.org.uk/projects/reports/registers/.
[11] European Commission, “Semantic Interoperability” in Glossary, n.d., https://interoperable-europe.ec.europa.eu/collection/portal-support/glossary/term/semantic-interoperability#:~:text=The%20European%20Interoperability%20Framework%20(EIF,grammar%2C%20format%2C%20and%20schemas; Global Coalition to Fight Financial Crime (GCFFC), London Stock Exchange Group (LSEG), and Open Ownership, Background paper: Taskforce on interoperable beneficial ownership data (GCFFC, LSEG, and Open Ownership, forthcoming).
[12] UK Government, “HM Land Registry”, n.d., https://www.gov.uk/government/organisations/land-registry.
[13] RIK, “E-Land Register Portal”, n.d., https://www.rik.ee/en/e-land-register/e-land-register-portal.
[14] RoS, “Register of Persons Holding a Controlled Interest in Land”, last updated 21 July 2025, https://www.ros.gov.uk/our-registers/register-of-persons-holding-a-controlled-interest-in-land-rci.
[15] Land Title and Survey Authority of British Columbia, “Land Owner Transparency Registry”, n.d., https://landtransparency.ca/.
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