Attention
This is v0.2 of the Beneficial Ownership Data Standard. It includes updates to the data model and additional codelist information. Implementers should be aware that future changes are anticipated, before a version 1.0 release. See the Changelog and About pages for more information.
MUST and SHOULD are used in the schema to denote required and recommended elements of the Standard, as defined in RFC2119.
The concept of a ‘statement’ is at the heart of the Beneficial Ownership Data Standard. BODS data consists of a collection of ordered statements describing:
Details of how an interested party controls or owns a company or other legal entity are wrapped in an ownership-or-control statement.
Details of the subject of an ownership-or-control statement and its interested party are wrapped in their own statements. The ownership-or-control statement refers out to these statements, acting as a connector.
Together, the statements above tell us that Roberto Lopez has some kind of controlling or ownership stake in RENCO Energy Ltd.
The schema reference defines in detail the fields that each statement should have, and how they should be structured.
Each statement represents a claim about beneficial ownership made by a particular source at a particular point in time.
Modelling beneficial ownership information in this way allows us to make sense of data received from multiple sources over extended periods of time. In particular, it allows:
When representing data conforming to BODS, users therefore need to handle statements with due care. Ultimately it is up to data consumers to decide which statements to trust, and to verify identities using the identifying information contained in personStatements
and entityStatements
.
Statements are specified in the data schema as JSON objects:
Each statement has a statementIdentifier
and statementType
field. The statementIdentifier
exists solely for the purpose of connecting statements.
statementIdentifier
references.All statements have source
and annotations
properties which can provide an audit trail describing where information was obtained from, when, and any verification of the information that has taken place. See Sources and annotations for guidance.
personStatements
and entityStatements
both contain a set of fields that can be used to disclose the real-world identity of the entity or individual. These include:
identifiers
array that is used to provide known identifiers such as company registration for firms, or publicly shareable taxpayer identifiers for individuals.Including such identifiers allows intelligent integration of information across disclosures, datasets and time.
These fields are designed to support ‘strict’ and ‘relaxed’ validation, to accommodate different data sources. New data sources should seek to provide the data required for strict validation, such as country codes, and full dates. Other sources should provide as much data as possible, subject to relevant policy and privacy constraints.
An ownershipOrControlStatement
connects (via statementIdentifier
references) the subject
of the statement (an entity described by an entityStatement
) and an interestedParty
. This interested party may be:
entityStatement
;personStatement
; orThe ownership-or-control statement also contains an array of interests
, each with a type (selected from the interestType codelist) and, where relevant, percentages indicating the size of the interest.
To explore the structure of the data model in full use the Schema browser. Or read the Schema reference for detailed definitions of each object and field.
In some cases ownership or control is exercised through:
Depending on the particular jurisdiction these are covered by, they may or may not have a registered legal identity.
In BODS arrangements such as these are treated as a special kind of entityStatement
with entityType
value: ‘arrangement’.
This allows control via arrangements to be modelled in two steps, describing how:
For more guidance on modelling arrangements, contact the BODS Helpdesk.
BODS can be used to describe both direct ownership and control (where Person A has a direct share in Company B), or indirect ownership and control (Where Person A is an ultimate beneficial owner of B, but where there may be any number of known or unknown intermediate companies or arrangements). This is indicated by use of the interestLevel
property that can be set for each interest declared.
Published BODS statements should be treated as a write-only ledger, with new statements being issued to amend data contained in older statements and those new statements appended to the ledger. See Updating statements for further guidance.