Effective consultation processes for beneficial ownership transparency reform


Commitments to beneficial ownership disclosure should be ambitious, specific and achievable, and clearly articulate the policy objectives and intended benefits. Commitments are stronger when they are mutually reinforcing with relevant international standards, such as the Extractive Industries Transparency Initiative (EITI) Standard and the Principles for Effective Beneficial Ownership Disclosure. Achievable commitments build on the current context (for example, if a non-public register already exists, a commitment is made to making it publicly available as open data).

Effective beneficial ownership disclosure, and the underlying policy and legal work required to achieve it, are rarely delivered by a single department or agency in government. Coupled with this, the efficacy of the reform relies on the use of new data by a broad range of stakeholders. As such, there is scope at the ‘Commit’ stage for government-related agencies and departments, civil society and business to make commitments to deliver reform. However, throughout the process it is important to have a clear understanding of which agency or department is the lead for implementation.

Conventional written consultation (online or offline)

Respondents are asked to give their view on a range of specific questions about the nature of the proposed commitment.

Likely audiences

This approach is likely to engage those groups already aware of the issues around beneficial ownership:

  • Civil society
  • Professional service providers and businesses/business groups most impacted by reform
  • Academia

Utilise existing multi-stakeholder fora

Use these fora to gather views on proposed commitments and create an opportunity for other groups to commit to supporting the effective delivery of the reform. Connecting the reform process to established networks with shared interests can increase buy-in and improve sustainability of the reform process.

Likely audiences

This approach is likely to engage those groups already aware of the issues around beneficial ownership. Where existing multi-stakeholder groups exist, these should be considered opportunities for engagement. These might include:

  • Chambers of Commerce or other groups of business
  • OGP Multi-stakeholder Forum
  • EITI Multi-stakeholder Groups
  • Anti-Money Laundering and anti-tax evasion fora

Key outcomes of the ‘commit’ stage

  1. Clear, time-bound, measurable commitments to beneficial ownership transparency are made and meet well-defined policy goals and incorporate feedback from stakeholders.
  2. A named lead agency for implementation of the reform and clearly defined roles for other agencies involved in aspects of delivery.

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