Proposal: European unique identifier (EUID)

[StephenAbbott]

Proposal

What open data standard are you working with? (e.g. 'OCDS', '360Giving', 'BODS' etc.)
BODS

The name of the list (or the organization that manages the list)
European unique identifier (“EUID”)

A suggested code for the list (optional)
eu

A short description of the list
Directive 2019/1151 of the European Parliament amending Directive (EU) 2017/1132 as regards the use of digital tools and processes in company law sets out in article 16 of section 1A that:

Member States shall ensure that companies have a European unique identifier (“EUID”), referred to in point (8) of the Annex to Commission Implementing Regulation (EU) 2015/884CCC (*2), allowing them to be unequivocally identified in communications between registers through the system of interconnection of registers established in accordance with Article 22 (“the system of interconnection of registers”). That unique identifier shall comprise, at least, elements making it possible to identify the Member State of the register, the domestic register of origin and the company number in that register and, where appropriate, features to avoid identification errors.

The 'system of interconnection of registers' mentioned in the quote above is the Beneficial Ownership Registers Interconnection System (BORIS). The central BORIS will be a closed system which "will reuse the eIDAS communication protocol with an additional BORIS-specific header (yet to be defined by the Commission), and preferably use the CEF eID Building Block to implement it" (quote from document linked above).

The unique identifier for the purpose of communication between registers shall be referred to as the EUID (European Unique Identifier).

The structure of the EUID will be compliant with ISO 6523 and will contain the following elements (see article 8 of Annex for details)

EUID element	Description	Additional description
Country code	Elements making it possible to identify the Member State of the register	Mandatory
Register Identifier	Elements making it possible to identify the domestic register of origin of the company and of the branch respectively	Mandatory
Registration number	Company/branch number refers to the registration number of the company/branch in the domestic register of origin	Mandatory
Verification digit	Elements making it possible to avoid identification errors	Optional

The EUID shall be used to unequivocally identify companies and branches for the purpose of the exchange of information between registers via the platform.

The country or countries that the list covers
European Union member states

The legal form or organizations that the list covers
All companies registered on the beneficial ownership/company registries in obliged European Union member states.

Any specific sectors that the list covers
Depends on country-specific legislation relating to BO transparency in the relevant European Union member states.

A URL for information on the list, and a URL for looking up identifiers (if available)
https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021R1042

Any information on available open data copies of this list
No open data copies of the list available as far as I know.

One or more examples of identifier from this list, and how you found them
No sample identifiers given. I found out about this via Directive 2019/1151.

[kd-ods]

So this EUID will be based on domestic registers' company numbers. Of the top of my head I can't remember what we've done in the past with such 'derivative' IDs, and whether we've added them to org-id.

(In the meantime, there is work ongoing with the Open Contracting Data Standard to ensure that all relevant iso-6523-compliant registers are added to org-id.)