The U.K. Companies (Miscellaneous Reporting) Regulations 2018, which came into force in September 2019, represented what many policymakers considered a significant, if somewhat understated, step toward greater corporate transparency. While not as headline-grabbing as some of the government’s other corporate governance reforms, these regulations introduced a key requirement: that beneficial ownership information (BOI) for companies be made available in searchable online registers. The underlying idea was simple enough—shine a light on who truly controls companies operating in the U.K.—but as is often the case, translating principle into practice proved to be the more challenging part.
By 2020, as the first full reporting cycles under these regulations began to take shape, the conversation shifted from compliance to utility. What, exactly, should be done with this wealth of newly accessible data? In the context of public procurement, this question became especially urgent. Procurement officers found themselves under increasing pressure to ensure that contracts weren’t being awarded to entities with opaque, or worse, suspect ownership structures. The Companies House open API, offering near real-time BOI, suddenly became not just a regulatory artifact, but a practical tool for due diligence.
For public procurement offices, integrating BOI checks into supplier vetting processes began with system design. There was no single, universally adopted method, but certain common practices emerged. Most offices chose to link their existing supplier master databases to the Companies House API, allowing for automated queries at the point of supplier registration. Some opted for batch processing—periodically cross-checking lists of suppliers against the BOI data. Others took a more continuous approach, flagging discrepancies or gaps in ownership records as they arose. The key, in either case, was to ensure that beneficial ownership verification wasn’t treated as a one-time task, but as an ongoing process.
Instructions circulated on how best to structure these checks. The first step, typically, involved pulling basic BOI data for each supplier—names of beneficial owners, percentages of ownership, and control markers such as voting rights or directorships. But raw data alone was rarely enough. Procurement teams were advised to compare this data against internal risk profiles, industry watchlists, and, where appropriate, external databases tracking politically exposed persons or sanctioned entities. There was, inevitably, a balance to be struck between thoroughness and efficiency. Too many checks risked slowing procurement to a crawl; too few left offices exposed to criticism—or worse.
An important development during this period was the move toward publishing monthly verification logs. This wasn’t, strictly speaking, a requirement under the 2018 Regulations, but it became something of a best practice among more proactive procurement bodies. These logs, typically made available on departmental websites or government procurement portals, served multiple purposes. Internally, they provided an audit trail, documenting the steps taken to vet new suppliers. Externally, they offered a measure of reassurance to stakeholders and the public that procurement decisions were being made with transparency in mind. Templates for these logs varied, but most included basic supplier identifiers, dates of verification, summary findings, and notes on any follow-up actions required.
Designing a robust monthly log wasn’t without its difficulties. Data privacy concerns loomed large, particularly when dealing with sensitive ownership information. Procurement offices had to tread carefully, ensuring that logs provided meaningful information without inadvertently disclosing personal or commercially sensitive data. Some chose to publish only aggregate statistics—such as the number of suppliers vetted and the percentage flagged for further review. Others provided more detailed breakdowns, but with identifying details anonymized or redacted. There was no one-size-fits-all solution, and approaches continued to evolve in response to feedback and shifting legal guidance.
What’s worth noting is how this focus on real-time transparency began to reshape supplier relationships. For many suppliers, especially SMEs not accustomed to this level of scrutiny, the new requirements prompted a closer look at their own ownership structures. Some undertook internal reviews or sought legal advice to ensure their BOI filings were accurate and up to date. Others found themselves fielding questions from procurement offices that, in previous years, might never have arisen. This, in turn, contributed—albeit in a gradual, uneven way—to a broader culture shift around corporate transparency in the U.K.
Yet challenges remained. Discrepancies in BOI records were not uncommon, particularly among companies with complex or international ownership chains. Procurement officers, often working under tight timelines, sometimes struggled to determine whether such discrepancies reflected benign administrative errors or something more concerning. There was also the question of resourcing. Effective BOI checks required not just access to data, but staff with the skills and time to interpret that data meaningfully. Smaller procurement units, in particular, found this difficult to sustain.
And then there were the grey areas. For instance, what should a procurement office do if a supplier’s BOI appeared incomplete but there was no clear evidence of wrongdoing? Should contracts be delayed while the matter was investigated, or should business proceed with caveats and conditions attached? Different offices answered these questions in different ways, reflecting variations in risk tolerance, legal advice, and political oversight. This lack of uniformity may have frustrated some observers, but it also reflected the complexities of marrying transparency with operational pragmatism.
As 2020 drew to a close, it was clear that the Companies (Miscellaneous Reporting) Regulations 2018 had achieved more than simply adding another layer of compliance. They had, at least in part, reoriented how procurement professionals thought about supply chain integrity. The integration of real-time BOI checks and the adoption of monthly verification logs marked a significant, if still evolving, shift toward proactive supply chain governance in the U.K.’s public sector.