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Availability: Beneficial ownership

The following indicator is under consideration for this pilot edition of the Barometer: To what extent is company beneficial ownership information available as structured open data?

Feedback on draft Global Data Barometer Indicators

You are looking at a draft indicator to be included in the expert survey of the Global Data Barometer. Between now and May 10th we are inviting your feedback on this indicator and the elements it contains. You can provide your feedback by (a) completing the feedback form below; or (b) adding in-line annotations.

Feedback form

You can share your feedback on the Availability: Beneficial ownership indicator here, or make use of Hypothes.is annotations

Show/hide supporting questions

Existence

  • Is this data available online in any form?
    • Data is not available online
      Supporting questions: Are there other offline ways to access this data in the country? (e.g. attending an office to inspect it)
    • Data is available, but not as a result of government action
      Supporting questions: If government is not providing access to data, how is this data available? Please provide a URL for where this data can be found
    • Data is available from government, or because of government actions
      Supporting questions: Please provide a URL for where this data can be found

Elements

Part 1: Dataset specific

  • The dataset contains unique identifiers for each company (No, Partially, Yes)

  • The dataset contains identifying information for each beneficial owner (No, Partially, Yes) Answer 'Partial' if a dataset contains only names and address or nationality. Answer 'Yes' if you find inclusion of other key identifiers such as Date of Birth (at least month and year), National ID Number or other persistent identifier.

    Supporting questions (conditional)

    If Partially or Yes: Please list the identifying information provided.

  • The dataset contains details of the interests held by each beneficial owner (No, Partially, Yes)

  • Data includes information about individuals' sex or gender. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially or Yes: Please briefly describe what data includes sex or gender information.

  • The data is published according to one or more relevant data standards (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially or Yes: Which standards are in use?

Part 2: General checklist

  • Data is provided in machine-readable format(s) (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially or Yes: Please provide a URL where this machine-readable data can be found. (Additional URLs can be included in the justification and supporting evidence)

    If Partially or Yes: Please provide a comma separated list of the formats available? (E.g. csv, json)

    If Partially: What prevents you from assessing this data as fully machine-readable?

  • Is this data available online in any form? (Data is not available online, Data is available, but not as a result of government action, Data is available from government, or because of government actions)

    Supporting questions (conditional)

    If Data is not available online: Are there other offline ways to access this data in the country? (e.g. attending an office to inspect it)

    If Data is available, but not as a result of government action: If government is not providing access to data, how is this data available?

    If Data is available, but not as a result of government action or Data is available from government, or because of government actions: Please provide a URL for where this data can be found

  • The machine-readable dataset is available as a whole (No, Partially, Yes) Answer no if it's only possible to access individual records; Answer partially if it's possible to export extracts of the data; Answer yes if there are bulk downloads or APIs providing access to the whole dataset without financial, technical or legal barriers.

    Supporting questions (conditional)

    If Partially or Yes: Please provide a URL where bulk download access is available or described.

    If Partially or Yes: If bulk access is provided through an API, please provide a link to where the API is described.

  • Data is openly licensed. (No, Partially, Yes)

    Supporting questions (conditional)

    If No: If there are explicit restrictions placed on re-use of the dataset, briefly describe those here.

    If Partially or Yes: If the data is provided with an explicit open license, please provide the name of the license, or a link to it here.

  • Data is timely and updated. (No, Partially, Yes)

    Supporting questions (conditional)

    When was the most recent update to this dataset?

  • There are accessible and open official tools available to help users locate and explore individual records. (No, Partialy , Yes) Answer 'partially' if tools make it possible to get at extracts of data without having to download a full dataset. Answer 'yes' if there is an interactive tool that displays user-filtered extracts of the data to answer simple questions without downloading data at all.

    Supporting questions (conditional)

    If Partialy or Yes: Please provide URL

    If Partialy : What are the main barriers to accessibility and usability?

  • Data is available in all the country’s official or national languages. If the country has no official or national languages, data is available in the major languages of the country. (No, Partially, Yes)

    Supporting questions (conditional)

    If Partially or Yes: Please briefly describe the language coverage available.

Extent

  • How comprehensive is the data assessed for this question?
    • The data assessed covers one or more localities, but there are many other localities without available data, or with data of a lesser quality.
      Supporting questions: Which locality does this data cover?
    • The data assessed covers one or more localities, and is a representative example of the kind of data that can be found for all, or most, localities.
    • The data assessed provides national coverage.

Definitions and Identification

A beneficial ownership register should contain details of the natural persons who have an ownership or control stake in registered companies.

Currently existing registers may apply to all companies in a jurisdiction, or only to a small sub-set, such as companies involved in the extractives industry, another regulated sector, or in receipt of public procurement contracts.

Starting points

  • Sources:
    • The OpenOwnership map links to a number of public registers of beneficial ownership (but is not exhaustive or always entirely up to date)
    • Global Witness reporting on EU Beneficial Ownership registers from March 2020 includes links to a number of available registers
    • The Stolen Asset Recovery Initiative resource library (search for 'beneficial ownership' and filter by country) contains a series of country guides (developed in 2016/17) aimed at public authorities seeking to access company and beneficial ownership information across borders. These can provide context on the kinds of data collected, and (as of their time of publication) accessible to the public.
  • Search:
    • Search the website of the National Company Register or Registrar for mentioned of beneficial ownership or related terms
    • 'Beneficial ownership' + [country]
    • 'Ultimate beneficial owner' + [country]
    • Beneficiary owners + [country]
  • Consult:
    • Transparency campaigners

What to look for?

Look for evidence that can answer the following questions:

  • Are the public able to access beneficial ownership information, or is it only provided to certain parties (e.g. law enforcement)?
    • Note: in cases where a register exists but is not public, the best sources of info for this are likely to be Anti-Money Laundering (AML) industry and government announcements about relevant legislative changes.
  • Is the data from the register available? Or only a search interface?
  • Is data available in bulk? Is there an API available?
  • Does the available data cover all companies, or only those that registered or updated their records after a certain date?

National and sub-national considerations

Where company registration is a sub-national responsibility, beneficial ownership registers may also be maintained sub-nationally. In these cases, look for and assess the best case example of data availability, and use the extent sub-question to indicate whether this represents common practice or not.

In cases where neither national nor sub-national government maintain registers, but data is available for a particular sector (e.g. extractives), carry out your assessment for that sector, and use the extent sub-question to indicate whether this represents common practice or not.

See the justification for Governance: Beneficial Ownership.