The EU is aligning beneficial ownership data formats — but without a data standard, harmonisation will fall short
The European Commission recently closed a public consultation on the formats EU member states should use when collecting beneficial ownership information in their central registers.
The draft implementing regulation, published alongside the consultation, lays out a set of common data fields and format requirements that registers across the bloc will need to follow from July 2027.
The regulation recognises that common formats are needed “to provide clarity for entities that have an obligation to report their beneficial ownership to the central registers, ensure consistent quality of data collected and increase the interoperability of the central registers”.
But specifying a list of fields and their data types is not the same thing as adopting a data standard — and the difference matters for anyone who needs to connect, exchange or analyse this information across borders.
Fields are not enough
The draft regulation defines what data should be collected: names, dates of birth, addresses, ownership percentages, interest types. It specifies date formats and ISO country codes. These are sensible choices.
What it does not do is specify how all of these elements relate to each other in a coherent data model. Each member state will still need to decide how to structure its registry data, how to represent indirect ownership chains, how to link natural persons to legal entities through intermediary companies, how to capture complex corporate structures and how to handle updates over time.
Without a shared model, the same information will be structured differently in every country — making cross-border exchange and analysis far harder than it needs to be.
The consultation itself hints at this gap. On complex ownership structures, the draft allows registers to collect information “by means of structured or unstructured data fields or file uploads,” acknowledging that flexibility is needed but stopping short of coordinating what that structure should look like.
A standard already exists
The Beneficial Ownership Data Standard (BODS) was built to solve exactly this problem. Developed since 2016 by Open Ownership in partnership with Open Data Services, BODS provides a complete data model for representing who owns and controls legal entities and legal arrangements — handling direct and indirect ownership, trusts, nominee relationships, temporal changes and complex multi-layered corporate structures as machine-readable, structured data.
BODS is endorsed by the World Bank, OECD, UNODC and G7 governments including the UK and Canada. It is already in use by the central registers of Armenia, Bermuda and Botswana, and the UK has formally adopted it as its open standard for beneficial ownership data.
Every data field in the Commission’s draft regulation can be captured in BODS — and the standard goes further, offering codelists for interest types, guidance on identifier schemes, support for multiple name types and a framework for recording why beneficial owners cannot be identified.
Why this matters for the EU
EU member states face a July 2027 deadline to implement the new AML package. They will need to build or upgrade their central registers to collect data in the formats the Commission specifies. If each country builds to the regulation’s minimum requirements using its own bespoke data model, interoperability will remain aspirational.
The BORIS interconnection system — designed to link national registers — will struggle to deliver meaningful cross-border data exchange if the underlying data is structured differently in every jurisdiction.
Adopting BODS would give member states a ready-made, internationally recognised framework that satisfies the regulation’s requirements while ensuring data can flow seamlessly between registers, into the BORIS system and across to non-EU jurisdictions that are also aligning with the standard.
The results of the Commission’s consultation have not yet been announced. Whatever the outcome, the case for EU member states to adopt a common data standard rather than 27 different interpretations of the same field list is only getting stronger.
For four years, I was the product owner of the Beneficial Ownership Data Standard, the world’s leading open standard for beneficial ownership information and continue to advocate to improve beneficial ownership data quality and standardisation. To learn more or if you need technical guidance or consultancy support, contact me via beneficialownership.co.uk.
