Understanding beneficial ownership data use
Implications for reforms
This section summarises reflections on how policy makers and the agencies in charge of implementing BOT reforms can meet the widest range of user needs identified in this research. It also reflects on the need to continue collecting evidence on the impact of BOT reforms by testing these research findings through user research at the domestic level.
Recommendations
Reducing obstacles to BO data use
BO data users currently face a number of challenges to effectively use BO information. Policy makers and agencies implementing BOT reforms should invest in reducing current obstacles, frictions, and resource costs of BO data use. These include considerations to:
- Provide well-designed APIs and up-to-date bulk downloads to enable large-scale processing, and to allow intermediary users to provide critical services to end users, including governments. To offset the cost of these features, registers can explore charging commercial users for access and use. Streaming APIs can be particularly useful to enable large-scale analysis on an ongoing or recurring basis. Automated alerts in BO registers can also support other use types that require monitoring changes over time.
- Expand the search functionality of BO registers to enable users to find the information they need. More extensive search functionalities can sometimes remove the need for APIs or bulk data. Basic public search portals with limited ways to process BO information can satisfy some user questions, but are unlikely to enable a wide range of use types that can lead to impact.
- Structure data in a well-defined way. [83] Capturing data that is well structured means it is predictable and easier to use. This also provides a basis to represent and understand change over time.
- Verify information at the point of submission of a BO declaration. As all BO data users require a baseline level of data accuracy to have some level of confidence in reaching their conclusion, setting up measures to support the elimination of errors and inconsistencies at the point of submission is key to supporting BO data use. Collecting information in well-designed digital forms also helps prevent accidental errors. This should be a priority for investment in any verification regime. More advanced verification mechanisms can be considered and should be informed by data use practices.
- Ensure effective mechanisms are in place to support entity resolution by using or assigning reliable identifiers for legal vehicles and individuals. Register-level identifiers are helpful to uniquely identify individuals in a single dataset, and can decrease the need for access to additional attributes and personal data. When users need to combine information across multiple data sources, especially across jurisdictions, additional attributes are still required.
- Foster interoperability across BO registers and with other data sources at domestic, regional, and international level. Some of the recommendations above help improve interoperability, including those related to structuring information, verification, and entity resolution. The following should also be considered:
- Investing in standardising data. Using a standardised way to structure data across multiple datasets lowers the resources required to join information sources. [84]
- Improving inter-agency coordination and ensure the use of common identifiers in different information sources, such as the LEI, developed by the Global Legal Entity Identifier Foundation (GLEIF).
- Improving inter-governmental cooperation on these topics, including exploring privacy-sensitive solutions to uniquely identify individuals at a transnational level. For example, the EU’s European Digital Identity.
- Design access provisions that allow users who have a role in achieving intended policy goals to effectively process BO information.
- This should include data-service providers who currently play a key role in the BO data-use ecosystem and are likely to continue doing so.
- Allow relevant users to flexibly use the information they need with necessary safeguards. Excessive or poorly designed safeguards can negatively affect the impact of BOT reforms. In addition, providing access to a public portal with limited searchability will satisfy most simple queries.
- Improve inter-governmental cooperation to develop legal and technical frameworks for accessing information across borders.
- Include all relevant legal vehicles within the scope of disclosure requirements.
Many of these aspects are covered in Open Ownership’s resources and guidance. [85]
Investing in user-centred policy design
Agencies implementing BOT reforms should invest in user research and contextualise the findings of this research to their contexts, as well as document and share this process. To achieve this, increased and sustained engagement with users at various points of the implementation process is essential, through:
- dedicating appropriate resources for ongoing user research;
- adopting an agile approach to implementation by listening to users’ feedback and learning from practice to make iterative improvements;
- monitoring and measuring data use, including by intermediary users;
- documenting user experiences to inform improvements to reforms.
User research can be conducted at any stage of implementation (see Figure 3). Whether BO information is already available to data users or not, agencies in charge of implementing BOT reforms can and should conduct some degree of user research. [86]
Figure 3. User research at different stages of implementation
Footnotes
[83] Jack Lord and Tymon Kiepe, Structured and interoperable beneficial ownership data (Open Ownership, 2022), https://www.openownership.org/en/publications/structured-and-interoperable-beneficial-ownership-data/.
[84] Lord and Kiepe, Structured and interoperable beneficial ownership data.
[85] For example, Open Ownership has guidance on verification, structured and interoperable data, auditable record of changes over time, the value of reliable identifiers to uniquely identify legal vehicles, and emerging good practices on identifiers to uniquely identify individuals and support agencies implementing BOT reforms with provisions to improve disambiguation in the register. See: Tymon Kiepe, Verification of beneficial ownership data (Open Ownership, 2020), https://www.openownership.org/en/publications/verification-of-beneficial-ownership-data/; Lord and Kiepe, Structured and interoperable beneficial ownership data; Armstrong, Building an auditable record of beneficial ownership; Armstrong and Abbott Pugh, Using reliable identifiers for corporate vehicles in beneficial ownership data; Rialet, “Denmark’s comprehensive approach to beneficial ownership transparency” in Use and impact of public beneficial ownership registers: Denmark (Open Ownership, 2023), https://www.openownership.org/en/publications/use-and-impact-of-public-beneficial-ownership-registers-denmark/denmarks-comprehensive-approach-to-beneficial-ownership-transparency/. Open Ownership’s Beneficial Ownership Data Standard (BODS) also provides a concrete solution for governments to move towards collecting, storing, and publishing structured and interoperable data with historical records and visualisation tools. See: “Beneficial Ownership Data Standard (v0.4)”, Open Ownership, n.d., https://standard.openownership.org/en/0.4.0/; “Beneficial Ownership Data Standard – Key concepts”, Open Ownership, n.d., https://standard.openownership.org/en/0.4.0/standard/concepts.html; Open Ownership, Beneficial Ownership Data Standard visualisation library (Open Ownership, n.d.), https://www.openownership.org/en/publications/beneficial-ownership-data-standard-visualisation-library/.
[86] For more information on how to conduct user research, see: Open Ownership, A guide to doing user research for beneficial ownership systems (Open Ownership, 2024), https://www.openownership.org/en/publications/a-guide-to-doing-user-research-for-beneficial-ownership-systems/.