Data Standard / Key concepts

Key concepts

Attention

This is v0.4 of the Beneficial Ownership Data Standard. It includes updates to the data model, codelists, and technical guidance.

Future changes are anticipated before a version 1.0 release. See the Changelog and About pages for more information.

Two things inform the Beneficial Ownership Data Standard (BODS) data model:

  • what beneficial ownership information is

  • how it is processed and used

Understanding these concepts and the data model will help you publish high-quality data.

Beneficial ownership concepts

A natural person is a beneficial owner of an entity because of certain interests. These interests may be rooted in legal ownership, or come from controlling the entity, or using its assets. The relationship between the beneficial owner and the entity may be direct, indirect or both. Where it is indirect, intermediary entities, people and their relationships, are part of the beneficial ownership network.

People or entities are obliged in some jurisdictions to disclose their beneficial ownership. They declare this information to a designated agency. Each declaration is a set of claims about the entities, people and relationships within the subject’s beneficial ownership network. Information about those entities, people and relationships is captured by the agency in records which are updated as new claims are made.

A labelled diagram of a beneficial ownership network. Labelled as 'Subject of beneficial ownership network' is Company E. Labelled as 'Direct relationship' is a solid line connected to Person 2. Labelled as 'Interest' is the text '32% shareholding' which sits on that solid line. Company E is also linked to Company A by a solid line. And Company A is linked to Person 1 by a solid line. Labelled as 'Indirect relationship' is a dotted line connecting Company E to Person 1. The text '45% shareholding' sits on that dotted line. Person 1 is labelled 'Beneficial owner'. Company A is labelled 'Intermediary entity'.

BODS Statements represent claims

The highest level object in a BODS dataset is a Statement. Each Statement represents a claim made by a source at a particular point in time. The claim can be about one of three elements of a beneficial ownership network:

  • an entity (including companies, trusts and legal arrangements)

  • a person (natural persons who own, control or benefit from entities)

  • a relationship (consisting of interests between an entity and an interested party)

A relationship statement block (connecting a person and an entity) containing a source block with type-selfDeclaration and assertedBy value of Acme Industries Ltd. Statement also has statementDate of 2018-07-12

Representing beneficial ownership information in this way allows people to make sense of data received from multiple sources over extended periods of time. In particular, this model means that:

  • statements about beneficial ownership can conflict when they come from different sources

  • statements about beneficial ownership can overlap, referring to identical parties

  • historical beneficial ownership snapshots (to answer questions of ‘who knew what, when?’) can be produced. This is known as bi-temporal modelling.

Statements should therefore be considered immutable – presenting details about an element of beneficial ownership as claimed at a particular point in time.

To achieve this, each Statement produced by a data management system needs to include:

  • the details claimed about the entity, person or relationship, as stored by records in the system

  • information about the source, date and context of the claim

After publication, publishers do not edit a Statement to indicate an information update: they publish a new Statement with the updated details of the record.

Beneficial ownership records

Data management systems need to internally maintain their own record with an appropriate recordId string for each person, entity and relationship whose details are disclosed. The recordId has two purposes:

  • linking entities and persons via relationships

  • publishing information updates

See Record identifiers for full requirements.

Linking entities and persons via relationships

Stable recordId values in BODS Statements allow the structure of beneficial ownership networks to be derived from BODS datasets.

A person node is connected via a solid line to an entity node. A person statement block sits next to the person node. A relationship statement block sits next to the solid line. An entity statement block sits next to the entity node. Within the person statement, recordType is 'person', the recordId is 'p24d78ae012f1', and the recordDetails show that the person's name is 'Lev Yotsky'. Within the relationship statement, the recordType is 'relationship' and the recordDetails show that the interestedParty is the record with recordId 'p24d78ae012f1' and the subject is the record with recordId 'e3f199ad8e312'. Within the entity statement, the recordType is 'entity', the recordId is 'e3f199ad8e312' and the recordDetails show that the entity is called 'White Flag Holdings Corp'. These elements represent Lev Yotsky's relationship with White Flag Holdings Corp.

The Relationship statement holds recordId values for the interested party and the subject of a relationship.

Publishing information updates

As real-world beneficial ownership changes, agents submit updated details about people, entities and relationships to the data management system. Then the system updates its records accordingly and publishes a new BODS Statement, containing the relevant recordId, for each updated record.

People can then use recordId values to group Statements made over time to see what information was known when.

A person node is connected via a solid line to an entity node. A relationship statement block sits next to the solid line. A further two relationship statement blocks sit on top of the first. All three relationship statements have recordId 'r-d67fb1a-aa2f3da' and the recordDetails show that these statements are about a shareholding interest. The earliest relationship statement has statementDate '2018-07-12' and recordStatus 'new'. The next has statementDate '2019-11-01' and recordStatus 'updated'. And the final relationship statement has statementDate '2021-02-28' and recordStatus 'closed'.

Published BODS Statements build a write-only ledger, as new Statements are issued to amend or confirm details contained in older Statements.

See Information updates for full requirements.

Representing beneficial owners

In a BODS dataset, the fact that a natural person is a beneficial owner of an entity is represented by including this information in the Relationship statement linking the two.

It is possible to represent an entity’s declaration that it has no beneficial owners (according to a jurisdiction’s definition of a beneficial owner).

It is also possible to include in BODS datasets information about natural persons who are not beneficial owners. For example, where the managing officials of an entity are disclosed because nobody meets the jurisdiction’s definition of a beneficial owner.

See Representing beneficial owners for full requirements.

The data model

Use the Schema browser to explore the structure of the data model in full. Read the Schema reference for detailed definitions and requirements for each object and field.

The objects and fields of the data model allow you to represent a range of real-world situations. Explore related requirements in the Modelling requirements section.