Implementing beneficial ownership transparency in the Kyrgyz Republic extractives sector — findings and recommendations


This section covers our initial review of SCIESU’s existing database and technology, and sets out our central recommendation on data storage.

Storage of data

Storing data electronically in a structured format is key to unlocking its utility and creating an effective beneficial ownership regime. As much of SCIESU’s current data is not in a structured format, we have not assessed the extent to which data as currently collected maps to the Beneficial Ownership Data Standard (BODS) – a standard format for describing beneficial ownership information. We did however conduct an initial review of SCIESU’s existing database, and hold conversations with its developer, and from these it appears that SCIESU’s current database could be amended and enhanced to collect the required beneficial ownership data in structured BODS format.

In addition, our initial review of company identifiers for Kyrgyz Republic suggests that each company has a stable, unique identifier, although we await confirmation that this is the case for Kyrgyz branches of foreign companies.

Once data collected for the register is entered into SCIESU’s database, it should be stored using a data model informed by the Beneficial Ownership Data Standard (BODS), with unique, stable identifiers for each company and each beneficial owner. Statements about beneficial ownership of license-holding companies in the database should be non-destructively replaced rather than updated. This will make the data much more useful for SCIESU and other users, and ensure that SCIESU’s data aligns with emerging international best practice.

Recommendation 12: Publish information as structured data in BODS format, using unique, stable identifiers for all companies, branch companies and beneficial owners

Using BODS will ensure data is easily linkable to other datasets in this format, and can be shared simply and automatically to the Open Ownership Register. Annex B sets out three ways to do this. Open Ownership will work with SCIESU to identify and take forward the best option.

Open Ownership will support SCIESU in mapping the data stored in local systems to BODS and creating a BODS compliant data schema. SCIESU should then explore whether the best method for implementing these recommendations is to adapt the existing database or create a new database.

Open Ownership will also provide guidance on issuing identifiers for foreign-registered entities (e.g., a company listed on a stock exchange). The database should issue stable, non-semantic internal identifiers for natural persons that allow users to see when multiple licenses are beneficially owned by a single natural person.[11]


[11] These identifiers should act as surrogate keys, compatible with temporal databases, so that the actions of a single natural person can be tracked over time.

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