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Beneficial Ownership Registry (NO0061)



Action Plan: Norway Action Plan 2019-2021

Action Plan Cycle: 2019

Status: Active


Lead Institution: Ministry of Finance

Support Institution(s): NA

Policy Areas

Anti-Corruption, Beneficial Ownership, Fiscal Openness, Private Sector, Sustainable Development Goals, Tax

IRM Review

IRM Report: Norway Design Report 2019-2021

Starred: Pending IRM Review

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information

Potential Impact:

Implementation i

Completion: Pending IRM Review


Establish public register of the beneficial owners
Responsible body Ministry of Finance
What problem for the general public
is the commitment aimed to solve?
Lack of knowledge and the scarcity of available
information on the beneficial owners and ownership
structures of companies and enterprises in Norway
increases, among other things, the risk of misuse
for the purpose of corruption and economic crime,
including evasion and money laundering.
What is the commitment? Establish a publicly available register of beneficial
How will the commitment contribute
to solving the problem?
Increased transparency regarding the ownership and
control of companies and enterprises in Norway will
counteract the risk of misuse of the companies etc.
for the purpose of corruption and economic crime
by weakening the companies’ opportunity to conceal
ownership and transactions.
How is this commitment relevant to
the OGP’s fundamental values?
Release of more information
Improves the quality of the available information
Improves the availability of information, which makes
it easier for the general public to get a hold of it
Additional information The initiative is relevant to the UN Sustainable
Development Goal 16, Section 4.
Milestones Start date End date
Contact information
Person responsible from the
implementing body
Tobias Brynildsen
Entity Ministry of Finance
E-mail/Telephone / +47 22 24 45 68
Other public participants Ministry of Trade, Industry and Fisheries
– Christian Gløersen: / +47 22 24 65 56
Collaborative civil society
organisations, cross-sectoral
working groups, etc.

IRM Midterm Status Summary

8. Establish public register of the beneficial owners

Main Objective

"Establish a publicly available register of beneficial owners. Increased transparency regarding the ownership and control of companies and enterprises in Norway will counteract the risk of misuse of the companies etc. for the purpose of corruption and economic crime by weakening the companies' opportunity to conceal ownership and transactions."


No milestones provided

Editorial Note: For the complete text of this commitment, please see Norway's action plan at

IRM Design Report Assessment




Access to Information

Potential impact:


Commitment Analysis
This commitment aims to establish a publicly available register about the ultimate owners (UBO) of companies registered in Norway. It continues from a commitment in the third action plan (2016-2018) which resulted in proposals for the UBO register. In June 2018, the government submitted a law proposal [42] to Parliament, which was up for consideration in the parliamentary finance committee by the end of the third action plan period. [43] In March 2019, Parliament passed the Beneficial Ownership Act, mandating a publicly accessible register in user-friendly format.

This commitment is relevant to the OGP value of access to information, and is important in terms of fighting money laundering, tax evasion, and economic crime. While the establishment of a publicly available beneficial ownership register is verifiable, the commitment does not provide details on how it will be created, or the characteristics and functionalities of the new register. According to a representative from the Ministry of Finance, the ministry will commission a government agency to develop the technical solution of the register, while the ministry will issue regulations. [44]

If successfully established, the public UBO register could significantly improve the transparency and access to information on beneficial ownership in Norway and would fulfill a major long-term priority for civil society in Norway. [45] However, Norwegian civil society has criticised the Beneficial Ownership Act as only shareholders holding more than 25 percent of the shares would be obliged to register, and foreign trusts with indirect ownership in Norwegian companies will not be listed. [46]

The Beneficial Ownership Act is currently awaiting supplementary regulations concerning the location of the register as well as technical details for accessing its information. [47] To maximise the impact of the future UBO register, the IRM recommends the following next steps:

  • Ensure that data is published in open format and use the Beneficial Ownership Data Standard (developed by Open Ownership) to maximise the interoperability of the information and meet global norms. [48]
  • Introduce mechanisms to verify the accuracy of the information presented on the UBO register. Several OGP members, such as Denmark and Slovakia, have already developed verification mechanisms for their beneficial ownership registers. [49]
[43] Independent Reporting Mechanism, Norway End-of-Term Report 2016–2018, pg 29,
[44] IRM researcher, telephone interview with Tobias Brynhildsen, Ministry of Finance, 28 March 2020.
[45] IRM researcher, telephone interview with Ingrid Hjertaker, Tax Justice Norway, 1 April 2020.
[46] Ultimate Beneficial ownership, published by Tax Justice Network Norway,
[47] Transparency International Latvia, Transparency International Lithuania, and Open Knowledge Sweden (2019), Open Data and Political Integrity in the Nordic Region,, pg 59.
[49] Kristine Frivold Rørholt, Update – Beneficial ownership register act, Wikborg Rein,


  1. Archiving Documents

    NO0054, 2019, Capacity Building

  2. Making Energy Statistics Available

    NO0055, 2019, Anti-Corruption

  3. e-Access and Expansion

    NO0056, 2019, Access to Information

  4. Open Cultural Data

    NO0057, 2019, Access to Information

  5. Digital Spatial Planning

    NO0058, 2019, E-Government

  6. Streamline Public Procurement

    NO0059, 2019, Anti-Corruption

  7. Preventing Corruption

    NO0060, 2019, Anti-Corruption

  8. Beneficial Ownership Registry

    NO0061, 2019, Anti-Corruption

  9. User Orientation

    NO0045, 2016, Capacity Building

  10. Electronic Public Records (OEP)

    NO0046, 2016, E-Government

  11. Transparency Regarding Environmental Information

    NO0047, 2016, E-Government

  12. Starred commitment Disclosure of Financial Data

    NO0048, 2016, Access to Information

  13. Transparency Regarding Rainforest Funds

    NO0049, 2016, E-Government

  14. State Employees’ Ownership of Shares

    NO0050, 2016, Anti-Corruption

  15. Promote Freedom of Expression and Independent Media

    NO0051, 2016, Civic Space

  16. Country-By-Country Reporting

    NO0052, 2016, Anti-Corruption

  17. Starred commitment Register for Ultimate Beneficial Ownership

    NO0053, 2016, Anti-Corruption

  18. Public Review and Public Consultation

    NO0020, 2013, Capacity Building

  19. Registering and Preserving Digital Documentation Produced by Public Bodies

    NO0021, 2013, Access to Information

  20. The Norwegian Citizen Survey (Innbyggerundersøkelsen)

    NO0022, 2013, Public Participation

  21. Whistleblowing

    NO0023, 2013, Anti-Corruption

  22. Strengthened Information Exchange for More Efficient Crime Prevention and Combating

    NO0024, 2013, Justice

  23. Strengthening the Transparency of Public Authorities and Administration

    NO0025, 2013, Access to Information

  24. Egovernment with an End-User Focus

    NO0026, 2013, E-Government

  25. Plain Legal Language

    NO0027, 2013, Capacity Building

  26. Norwegian Grants Portal (MFA)

    NO0028, 2013, Aid

  27. An International Convention or Agreement on Financial Transparency

    NO0029, 2013, Private Sector

  28. Reducing Conflicts of Interests – Post-Employment Regulations

    NO0030, 2013, Anti-Corruption

  29. Centre for Integrity in the Defence Sector

    NO0031, 2013, Security & Public Safety

  30. A Better Overview of Committees, Boards and Councils – More Public Access to Information and Better Opportunities for Further Use

    NO0032, 2013, E-Government

  31. Modernizing Public Governance

    NO0033, 2013, Capacity Building

  32. Transparency in the Management of Oil and Gas Revenues

    NO0034, 2013, Anti-Corruption

  33. Transparency in the Management of the Government Pension Fund (GPF)

    NO0035, 2013, E-Government

  34. Transparency and Anti-Corruption Efforts

    NO0036, 2013, Anti-Corruption

  35. The Municipal Sector

    NO0037, 2013, Education

  36. “Simplify” (“Enkelt Og Greit”)

    NO0038, 2013, E-Government

  37. Electronic Public Records (OEP) – (Offentlig Elektronisk Postjournal)

    NO0039, 2013, Access to Information

  38. Re-Use of Public Sector Information (PSI)

    NO0040, 2013, Access to Information

  39. Access to Health Data

    NO0041, 2013, E-Government

  40. Renewal of the Government’S Website (Regjeringen.No – Government.No)

    NO0042, 2013, E-Government

  41. Declaration of Principles for Interaction and Dialogue with NGOs

    NO0043, 2013, Capacity Building

  42. Simplification and Digital Administration of Arrangements for NGOs

    NO0044, 2013, Capacity Building

  43. An Open Public Sector and Inclusive Government

    NO0001, 2011, Anti-Corruption

  44. Measures to Promote Gender Equality and Women’S Full Participation in Civic Life, the Private Sector, the Public Administration and Political Processes.

    NO0002, 2011, Gender

  45. Gender Equality – Participation in the Private Sector

    NO0003, 2011, Gender

  46. Increase Women's Representation in Local Government

    NO0004, 2011, Gender

  47. Gender Equality Program

    NO0005, 2011, Gender

  48. Gender Equality – Inclusion of Immigrant Women

    NO0006, 2011, Gender

  49. Gender Equality – Combat Gender Stereotypes

    NO0007, 2011, Gender

  50. Gender Equality – Youth Initiatives

    NO0008, 2011, Gender

  51. Gender Equality – Combat Domestic Violence

    NO0009, 2011, Gender

  52. Transparency in the Management of Oil and Gas Revenues / Financial Transparency

    NO0010, 2011, Aid

  53. Transparency in the Management of Oil and Gas Revenues / Financial Transparency – Government Global Pension Fund

    NO0011, 2011, Fiscal Openness

  54. Transparency in the Management of Oil and Gas Revenues / Financial Transparency – Combat Tax Evasion

    NO0012, 2011, Fiscal Openness

  55. Transparency in the Management of Oil and Gas Revenues / Financial Transparency – Multi-National Companies

    NO0013, 2011, Fiscal Openness

  56. An Open Public Sector and Inclusive Government – Create Central Communication Policy

    NO0014, 2011, Fiscal Openness

  57. An Open Public Sector and Inclusive Government

    NO0015, 2011, E-Government

  58. An Open Public Sector and Inclusive Government – Public Data Use

    NO0016, 2011, Public Participation

  59. An Open Public Sector and Inclusive Government – National Statistic Publication

    NO0017, 2011, Access to Information

  60. An Open Public Sector and Inclusive Government – National Public Opinion Survey

    NO0018, 2011,

  61. An Open Public Sector and Inclusive Government

    NO0019, 2011, Public Participation

Open Government Partnership