Determining date of beneficial owner for a Public Company

The provision relating to beneficial ownership reporting was first introduced when the Companies Act 2016 was enforced on 31 January 2017.

In this regard, if the person can determine the date in which he becomes a beneficial owner, he is required to state that actual date when he becomes the beneficial owner of the company even if the date was before 31 January 2017.

However, if the individual has taken reasonable steps to ascertain the date he becomes a beneficial owner but still unable to do so, the date that he becomes a beneficial owner is deemed to be 31 January 2017, being the enforcement date of Companies Act 2016. 

In the case where a person has reasonable cause to believe he is a beneficial owner at a date after 31 January 2017, then he needs to state that later date.

More information :

1. Guidelines for the Reporting Framework for Beneficial Ownership of Companies
2. Case Studies and Illustrations of the Guidelines for the Reporting Framework for Beneficial Ownership of Companies
3. Electronic Beneficial Ownership System ​(e-BOS)​​
4. Companies (Amendment) Act 2024
5. ​Practice Directive No. 9/2024: Lodgement of Beneficial Ownership Information under the Companies Act 2016 Through e-BOS
6. FAQ Beneficial Ownership​​
7. FAQ Companies (Amendment) Act 2024