Revisions to Draft Companies (Beneficial Ownership Information) (Amendment) Regulations 2021 – Public Consultation
Verification
A company shall take reasonable steps to identify its beneficial owners and shall enter in its register of beneficial owners the following particulars in respect of its beneficial owner
Centralised BO registers can help with simplifying and automating the verification process. The current regulations place an onus on companies to undertake this task, which is commendable. However, a dual system where the BRS is also able to verify data independently from the declarations made by companies would also support driving up the quality of data and data use.
To maximise the impact of BO data, it is important that data users and authorities can trust that the data contained in a register broadly reflects the true and up-to-date reality of who owns or controls a particular company. OO recommends that data should be verified on submission and updated – or confirmed that it still holds true – on a regular basis. Procurement officers want to be confident that the data is correct at the time of decision making, so data should at a minimum be (re)verified at that point in time (see OO guidance on verification).