Structured and interoperable beneficial ownership data

  • Publication date: 12 August 2022
  • Authors: Jack Lord, Tymon Kiepe


To maximise the impact of BOT reforms, a disclosure regime should collect, store, and publish BO information as structured data. This briefing highlights the policy benefits and advantages of these technical aspects of implementation. It provides considerations for implementers about what needs to be in place on a policy level in order to implement the systems and technology to support effective data collection, storage, publication, and use.

To summarise, structuring data creates information that is predictable, which makes it easy to work with and improves its functionality. These benefits apply to both technical and non-technical users. By removing some of the frictions associated with unstructured data, structured data decreases the cost of: collecting data for governments; compliance to disclosure requirements by legal entities; maintaining, publishing, and using the data; and realising policy benefits. It also ultimately facilitates greater policy impact of BOT reforms. Higher up-front costs associated with setting up the required systems are expected to be negated by lower costs associated with collection, storage, publication, use, and maintenance in the long run.

Structured BO data has a greater policy impact because it is highly interoperable. The inherent nature of beneficial ownership means it must be combined with other beneficial ownership and non-BO datasets to be of most value. Structured data also facilitates other aspects of disclosure, such as collection and verification. BODS is designed with interoperability at its core.

In order to operationalise structured BO data, implementers should create an enabling legal and policy environment; provide sufficient resources; and employ a user-centred and iterative approach. The data structure must be able to identify people, entities, and other relevant parties by using unique, permanent, and resolvable identifiers and other descriptive data fields. The structure should be able to describe the ownership and control relationships in sufficient, structured detail. Additional temporal data and metadata should also be collected to ensure auditability and interoperability. The technical systems, business processes, and database design should meet the full functionality and access expected from publication and data sharing, and due consideration should be given to this at an early stage. Finally, making the information available in a range of ways, choosing the right licence, and publishing information about licensing along with additional documentation and a data publication policy can maximise data use.

A growing number of jurisdictions are starting to publish structured BO data, including to BODS, which is increasing the contextual interoperability – and the utility and value – of the data. As more data becomes available, this information will be ingested into the OO Register, and OO will continue to document different use cases and impacts.