According to ERR, the Ministry of Finance intends to change public access through legislation. The report describes a proposed change, rather than confirmed final access conditions or an implementation date. ERR report.
In an earlier explanation, the Ministry stressed that beneficial ownership information would not disappear from registers. Under the proposed model, competent authorities and obliged entities would retain access, while access for those acting in the public interest would be linked to a legitimate interest. This explanation describes the objective of the change; the specific arrangements must be checked against the final legal framework. Ministry of Finance explanation.
Access rights and a functioning query process need separate attention
A bank, payment institution, crypto-asset service provider or other obliged entity may use register information directly, through a service provider or in an automated check. A change to the access model may therefore also require changes to working arrangements.
We recommend mapping:
- who makes queries within the firm and on what access basis;
- which checks depend on external data services;
- how query results and the time of verification are retained;
- how checks continue if information is temporarily unavailable;
- how discrepancies between register information and the customer’s explanations are resolved.
For example, a technical failure of a query should not automatically become a conclusion that a company has no beneficial owner. Such a situation requires separate handling and documentation.
The first preparatory step is to identify dependence on existing access. Final changes to procedures and systems should be linked to the adopted rules and the register’s actual technical solution.