Since 2020, every private BC company has been required to keep a transparency register — a list of the real human beings who ultimately own or control the company. Most owners have never heard of it. BC has legislated the next step — a public, registrar-filed version of the register, updated within 15 days of any change — but those 2023 amendments are not yet in force. Here is what the law requires today, and what changes when the new rules take effect.
What the transparency register is
It's not your shareholder list. The central securities register records legal ownership; the transparency register records significant individuals — people who, directly or indirectly, own or control 25% or more of the shares or votes, or who have the right to elect or remove a majority of directors. "Indirectly" is where it gets real: ownership through a holding company, a trust, a nominee, or an agreement among family members all counts, and interests of "associated" people (spouses, minor children) can be combined.
For a typical owner-operator company, the register is short and simple. For anything with a holdco, a family trust, or a 50/50 partnership with side agreements — it takes actual analysis.
What you must record today
Under the Act as currently in force, the register is a document kept at your records office. It is not public: it is available to the company's directors and to inspecting officials such as police and tax authorities, not to anyone who searches your company. For each significant individual it must record:
- Full name, date of birth and last known address
- Citizenship, and whether the person is a resident of Canada for tax purposes
- The date they became (and, if applicable, ceased to be) a significant individual
- How they qualify — the shares, votes or director-election rights, held directly or indirectly, that make them significant
No social insurance number is required. The company must also take reasonable steps at least once each financial year to confirm the register is accurate and complete, and update it within 30 days of becoming aware of new or different information.
What changes when the new rules take effect
In 2023 BC passed amendments (Bill 20) that will change three things. None of them is in force yet — the amendments have not been proclaimed and no filing window has opened. When they take effect:
- Filing goes online, with a public component. Instead of a document sitting (theoretically) at your records office, transparency information will be filed with the Registrar through the business registry, and part of it will be publicly searchable. Companies will be given a window to make their first filing.
- 15-day updates. When your company becomes aware of a change — shares sold, a shareholder dies, a trust is restructured — the filed register will have to be updated within 15 days, down from 30 today.
- Possibly more particulars. The list of information to record may expand when the amendments are brought into force. Collecting personal information from shareholders will be part of running a company.
The legislation includes omission mechanisms for people at risk (and minors), but they will have to be applied for — not assumed.
The uncomfortable questions to ask yourself
- Does your company have a transparency register at all? (If you incorporated online and never heard the term: no.)
- Has it been verified in the last year? Annual verification is required.
- If your shares are held through a holdco — does the holdco's register exist too, and does the operating company's register correctly trace through to the humans?
- Who in your company will notice when the public-filing rules are brought into force?
What compliance actually involves
For most small companies, getting compliant is a few hours of focused work once, then a maintained process: identify significant individuals (including through chains), collect the required personal data, document the reasonable steps you took, record verification dates, and update the register promptly when something changes (30 days today; 15 once the amendments are in force). The failure mode isn't usually willful — it's that no one owns the job.
That's the entire point of having a records office that does more than hold mail. The transparency register is included in both Minuted plans ($249 and $399/yr): we prepare it from your ownership information if it doesn't exist, keep it at our records office, run the annual confirmation, and update it when your ownership changes. When the public-filing rules are brought into force, we'll tell you before they take effect and handle the filing. Federal (CBCA) companies have an equivalent — the individuals with significant control (ISC) register — which we cover on our federal companies page.
Want the checklist version? Email hello@minuted.ca with "transparency checklist" and we'll send the one-page readiness checklist — and if you'd like, a free look at whether your company's register would survive scrutiny.
Minuted is a corporate records and filing service, not a law firm. Complex ownership structures may need legal advice — we'll tell you when, and refer you to someone good. General information, not legal advice.