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).