Access to up-to-date information
A company shall lodge with the Registrar the particulars of change of its beneﬁcial owners in Form BOF2 set out in the First Schedule and shall pay the fees set out in the Second Schedule.
The current regulations provide for a process where the BRS is notiﬁed of changes to beneﬁcial ownership data. The ability of competent authorities and procurement authorities to also be updated on changes to ownership and control of companies is equally important, particularly where an investigation or analysis requires information on changes of ownership over time.
In public procurement this may be important for on-going contract monitoring to ensure loopholes aren't created where ownership changes are used to conceal interests once a contract is awarded or where procuring entities requires up-to-date information for analysis. OO would therefore recommend a provision be included which allows for procurement and competent authorities to access up-to-date records, as well as historical records.