Leveraging shareholder data for beneficial ownership transparency

The case for better shareholder information

High-quality, centralised shareholder information can both strengthen BO disclosure regimes as well as have a wide range of benefits for the policy objectives BOT reforms are often seeking to achieve. This section provides a broad, top-level overview of these benefits.

Compliance and accuracy

Due to the overlap of shareholder and BO information, the former can be used to verify BO declarations, particularly for more complex, multilayered structures. BO declarations involving interests held through these types of structures are often unverifiable. Alternatively, shareholder information can be used to pre-populate or provide exemptions for BO declarations, thereby lowering the compliance burden and cost for reporting companies (particularly for those with a relatively simple ownership structure). [10]

In many of the policy objectives of reforms – e.g. tackling money laundering and illicit financial flows – BOT is often aiming to shed light on complex corporate structures, as these are where the risks are concentrated. While BOT targets complexity, in many jurisdictions there has been opposition to reforms due to the compliance burden on smaller businesses, and implementing agencies may seek ways to reduce these. In more complex structures, it will be easier for companies to report their direct owners, as they are more likely to accurately know who these parties are compared to the ultimate beneficial owners. This means information is also more likely to be accurate and up to date. Both of these use cases involve consolidating duplicate information, which may also benefit data users who may otherwise struggle with conflicting information.

Where jurisdictions hold companies’ shareholder information centrally, and where these registers have a constitutive effect – i.e. being named in the register as owning a share confers legal certainty, in a similar way to asset registers – the information can be expected to be highly accurate. [11] These registers can serve as a single source of truth and a backbone for digital public infrastructure. [12]

Understanding corporate networks

Shareholder and BO data can also be combined to understand full corporate networks: structured representations of how companies, individuals, and other entities are linked through intermediaries (see, for example, Figure 1). This is particularly the case where shareholder information is accessible across borders. [13] The availability of information on direct relationships is critical for building and combining these networks across data sources. Leveraging shareholder information may also help to provide a level of detail not visible in BO declarations, as well as removing the need to lower BO reporting thresholds to gain this detail. [14] Accurately understanding corporate networks can be particularly valuable for financial crime investigations. [15] This need also exists in use cases in public procurement, asset recovery, taxation, and customer due diligence (CDD). [16]

Improving the business environment

With respect to CDD, where company ownership information is highly accurate, particularly for simple structures, AML regulators can consider whether their regulated entities can rely directly on this information to meet their obligations for customer identification and verification. Rising compliance costs have made smaller loans – in the case of the Netherlands, up to EUR 100,000 – relatively costly for financial institutions. Changing CDD for simple, low-risk businesses may therefore unlock access to loans and capital for small and medium-sized enterprises.

These registers can also function as digital central securities depositories for the trading of shares. This can have benefits for investor protection and helping investors make sound decisions. [18] It may make the buying and selling of shares in private limited companies easier and more efficient. While it may help provide access to capital through broader participation in private companies, it may also introduce systemic risks and ratchet up trade volumes. In addition, it could help with organising quorate shareholder meetings, a common challenge of smaller companies. [19]

Despite this range of benefits, there are no known jurisdictions that have implemented a comprehensive approach to company ownership information and understanding corporate networks.

Footnotes

[10] Niek Zaman and Hannah Erdman, Een Centraal Aandeelhoudersregister (CAHR) als betrouwbaar en innovatief opstapje voor digitalisering van aandelen en een betere kapitaalinfrastructuur voor BV’s (Universiteit Leiden, 2020), 5–6, https://www.universiteitleiden.nl/binaries/content/assets/rechtsgeleerdheid/instituut-voor-privaatrecht/cahr-onderzoek-finaal-rapport-dd-25-november-2020.pdf.

[11] For BOT of assets, please see: Maria Jofre and Tymon Kiepe, Bridging the gap for effective asset transparency: Analysing land registers and beneficial ownership data for legal vehicles (Open Ownership, 2026), https://www.openownership.org/en/publications/bridging-the-gap-for-effective-asset-transparency/.

[12] Organisation for Economic Co-operation and Development (OECD), Digital Public Infrastructure for Digital Governments, OECD Public Governance Policy Papers No. 68 (OECD, 2024), 15, https://www.oecd.org/content/dam/oecd/en/publications/reports/2024/12/digital-public-infrastructure-for-digital-governments_11fe17d9/ff525dc8-en.pdf.

[13] For example, many commercial data service providers aggregate shareholder information to enable the understanding of corporate networks.

[14] Tymon Kiepe, “Solving the international information puzzle of beneficial ownership transparency”, Open Ownership, 17 June 2024, https://www.openownership.org/en/blog/solving-the-international-information-puzzle-of-beneficial-ownership-transparency/.

[15] Skatteetaten, Konseptvalgutredning: Eierskapsopplysninger aksjer (Skatteetaten, 2024), 20, https://www.skatteetaten.no/contentassets/b480645c1aec4e6f89c1226a57a70e76/2024-12-kvu-eierskapsopplysninger-aksjer-.pdf.

[16] UK government, Procurement Act 2023, Schedule 6, Part 3, para. 45, https://www.legislation.gov.uk/id/ukpga/2023/54/schedule/6/paragraph/45; European Banking Authority (EBA), Consultation Paper: Proposed Regulatory Technical Standards in the context of the EBA’s response to the European Commission’s Call for advice on new AMLA mandates (EBA, 2025), https://www.eba.europa.eu/sites/default/files/2025-03/9bc83e61-e9a1-4e91-93de-2af8325e0182/Consultation%20Paper%20on%20Response%20to%20Call%20for%20Advice%20new%20AMLA%20mandates.pdf; Isabelle Büchner, Chasing Grand Corruption (Transparency International, 2025), https://files.transparencycdn.org/images/Report-Chasing-Grand-Corruption-English-2025-Oct.pdf; Tymon Kiepe, Leveraging information about ownership networks to improve taxation (Open Ownership, 2025), https://www.openownership.org/en/publications/leveraging-information-about-ownership-networks-to-improve-taxation/.

[17] Zaman and Erdman, Een Centraal Aandeelhoudersregister, 4.

[18] SECP, “SECP Approves Full Digitization of Share Ownership”; Skatteetaten, Konseptvalgutredning, 31.

[19] Zaman and Erdman, Een Centraal Aandeelhoudersregister, 4–5.

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