Feature one: reliable and comprehensive dates and times
“What did the beneficial ownership of the company look like in September 2021?”
Answering a question like this means picking through historic information. It also requires a good understanding of how reported information reflects a timeline of real world events.
Broadly, dates and times in beneficial ownership ledgers tell us:
- When a feature of beneficial ownership existed
- When details of that feature were reported
- When the information was added to the ledger
For example, a person might divest from a company on a certain date and cease to be a beneficial owner. That information might be reported seven days later, but only be visible via a business register website ten days later.
Figure 2. Timeline of information flow
Publishing such dates as part of a ledger allows us to recreate timelines and to picture a company’s ownership and control at a particular point in time. When dates are published, therefore, it is important to be clear about what they mean. For example, consider a person's name alongside a date titled 'Beneficial ownership date'. It is not immediately clear whether that is the date on which their relevant interests in an entity started, ceased, or the date on which they were reported. A well-maintained publication policy or data-use guide can be a great help when it comes to interpreting information accurately (see the final feature below).
A good starting point when considering the kinds of dates that will need to be recorded by a declaration system are the reporting regulations of the country concerned. These should specify the particular events that trigger beneficial ownership information to be disclosed, updated or confirmed. For example, initial registration of an entity, a change of beneficial owner or annual reporting requirements might all trigger a declaration to be made. There are likely to be related sanctions for non-compliant reporting, so collecting accurate date information is critical for flagging non-compliance. This is covered in more detail in the paper ‘Designing sanctions and their enforcement’.
On a practical note, some dates might be captured within a declaration form (for example, ‘Date that individual ceased to be a beneficial owner’) whereas others might be metadata collected automatically by an online system (for example, ‘Date of declaration submission’).
The Beneficial Ownership Data Standard (BODS) supports the publishing of crucial dates relating to beneficial ownership declarations. Open Ownership will also be developing guidance on how to understand and use date fields across the data schema. All of this means that producing a point-in-time snapshot of a company’s ownership and control becomes a reliable and reproducible process.
- Registers should capture crucial dates for changes and should format these in line with internationally recognised standards such as ISO 8601.