Client intake Current

Requesting beneficial ownership information from a corporate client

Ask the way Corporations Canada expects the company itself to ask its own shareholders.

A federally incorporated client is expected to keep its own individuals-with-significant-control register up to date, and that means it already has, or knows how to get, the details you need to ask for. This guide sets out a practical approach to requesting that information. It is general information, not legal or compliance advice.

Action plan

1 Identify who you need beneficial ownership details on Start from the company's own register before asking for anything new.

Corporations Canada's guidance describes an individual with significant control as someone who owns, controls, or directs a defined share of the corporation, or who otherwise has influence that would amount to control in fact. Ask the client to share their current individuals-with-significant-control register as the starting point, rather than starting the identification exercise from a blank page.

  • Ask the client to share their current individuals-with-significant-control register first
  • Use the register to identify who needs further verification on your side
  • See the separate guide on what that register itself must contain

Done when: The client's current individuals-with-significant-control register has been requested and reviewed

Corporations Canada: individuals with significant control
2 Request the same details the company itself is expected to request Corporations Canada already sets out a working format for this request; reuse it rather than inventing your own.

Corporations Canada's guidance describes the company's own duty to take reasonable steps to keep its register accurate, including sending a request to its current individuals with significant control at least once a year asking them to confirm or update their information, and asking shareholders to confirm whether they have become an individual with significant control. Corporations Canada also provides a template request form for this purpose, which is a practical starting point for your own request to the client's shareholders or controllers.

  • Ask which individuals the company itself has already requested confirmation from
  • Reuse Corporations Canada's template request form structure where it helps
  • Request full legal name, date of birth, citizenship, tax residency, and address details, matching what the register itself must hold

Done when: Beneficial ownership details have been requested in a form matching the register's own required fields

Corporations Canada: individuals with significant control
3 Record what you asked for, when, and what came back A documented request trail matters as much as the answer itself.

Corporations Canada's guidance requires the company's own register to record the steps it took to keep the information current, which reflects the same discipline worth applying to your own request: keep a record of when you asked, what you asked for, and what was provided or left outstanding, so a gap in the answer is visible rather than assumed away.

  • Record the date beneficial ownership information was requested from the client
  • Record what was actually provided against what was asked for
  • Flag any individual who hasn't responded rather than treating the register as complete

Done when: A record exists of what beneficial ownership information was requested, when, and what was received

See requesting individual identity documents