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Information for Software Developers

The following information is intended to assist software developers in integrating the Register of Beneficial Owners into customer management programs, law firm software products, or other applications.

General

With the Register of Beneficial Owners, a very innovative solution has been implemented in Austria, providing an ideal starting point for the identification and verification of beneficial owners for all companies that have due diligence obligations for prevention money laundering and terrorist financing (obligated parties).

Reports to the Register are mainly (currently around 90%) made by professional party representatives (tax advisors, CPAs, lawyers, notaries, accountants, bookkeepers, payroll accountants and auditing associations (from 10 January 2020)) for their clients.

The possibilities described below are intended to enable obligated parties to call up the Register of Beneficial Owners (BORA) directly from their customer management programs, either manually or semi-automatically. In the future, professional party representatives will be able to submit reports for specific clients directly from their law firm software, retrieve extracts and import data semi-automatically.

Roles and rights management and payment of user charges are guaranteed in the background by the BORA Management System and therefore as a rule do not have to be implemented at the level of third-party systems. The web service is an exception in this respect, as it allows a company (a credit institution, a tax advisor, etc.) to query the register. When using the web service, care should therefore be taken to ensure that manual searches of the register can be carried out only by the staff responsible for the specific tasks.

If you have any questions regarding the implementation of the various technical possibilities or have ideas for future developments, please contact us at wiereg-registerbehoerde@bmf.gv.at or +43 (0) 50 233 775.

Note

The web service is not accessible via the web browser! A software solution must be programmed by your law firm’s software provider or your in-house IT department.

Integration of the BORA by means of deep links (extracts, management system, reporting forms):

So-called deep links allow excerps, reporting forms and the BORA Management System in future to be opened for a specific client/customer directly from the law firm software/customer management. The respective master number (register of companies, register of associations or supplementary register) is copied from the external system. The login mask in the Business Service Portal can also be filled by the external system, and thus a single sign-on can be implemented.

The following possible functionalities can be implemented for obligated parties:

  • Directly from the customer management, an extract can be opened for a specific customer, or the selection of the statement can be opened (simple/extended, historical data yes/no, and ID card copies)
  • The BORA Management System can be opened from the general part of the customer management in order to retrieve excerps from legal entities that are not clients, to search for individuals, to set notes, or to manage user charges
  • Automatic retrieval and storage of excerps at certain events, for example when a new customer is created
  • Automatic serial retrieval and storage of extended excerps from the register via batch file (being phased out: from 10 January 2020 only the web service should be used for this purpose)

For professional party representatives the following additional functionalities can be implemented:

  • The reporting form for a specific client can be opened directly from the law firm software
  • Automatic retrieval and storage of excerps after submission of a report for documentation purposes

Download of the technical documentation:

BORA web service (from 10 January 2020) and XML data (from 11 March 2020)

This web service offers interesting options for additional functions for machine-to-machine interactions and can be used by all obligated parties and professional party representatives. The prerequisite for this is the set-up of a web service account in the Business Service Portal, which is possible free of charge. The web service will be offered with two methods:

  • Synchronous query: For queries where an individual human user is waiting for a specific extract. The query is performed immediately
  • Asynchronous query: Is mandatory for all machine-based queries that are not ascribable to an individual human user (batch processing). The queries are queued and processed accordingly. Depending on the system load, there may be a time delay in the transmission of the statement.

The following possible functionalities can be implemented for obligated parties:

  • Directly from the customer/client administration, any extract can be opened for a specific customer (simple/extended, historical data yes/no). Copies of ID cards, from 10 November 2020 on also released compliance packages as *.zip files and the pro rata costs of an extract are transmitted.
  • With extended excerps, XML files containing all the essential data of extended statements are delivered at no additional cost. This enables interesting features such as automatic creation of new customers or automatic creation of jobs for the carry-over of changes when a signal is given by the change management service.
  • The XML files will also contain the representation of the relevant participation structure, which opens up interesting application possibilities:
  • Transfer of the data of the client/customer and its beneficial owners and top-level legal entities into law firm software products or other customer management programs
  • Transfer of the data of persons having power of representation and shareholders into law firm software products or other customer management programs
  • Transfer of the mapping of the relevant shareholding structure into law firm software products in order to create an editable version of the relevant shareholding structure, for example for compliance packages or as illustration for clients
  • Based on the XML data imported, statistical evaluations for the (law firm’s) internal risk analysis can be carried out. The ÖNACE code and the legal form of the entity, the domiciles and citizenships of the beneficial owners, the legal form, the ÖNACE code and the country of domicile of the top-level legal entities, the existence of trusteeships, etc. can be used to evaluate the client risk and the client structure in a standardised manner.
  • Automatic retrieval and storage of excerps at certain events, for example when a new customer is created.

For professional party representatives the following additional functionalities can be implemented:

  • Automatic retrieval and storage of excerps after submission of a report for documentation purposes.
  • After submission of a report with changes, and after a positive signal from the change management service, an extended extract can be obtained as an XML file, and the reported changes can be transferred to the law firm software.
  • Cash expenditures for queries from the Register of Beneficial Owners can be allocated to the respective client.

Download of the technical documentation

Change management service

The change management service is a web service that can be used by all companies. The prerequisite for this is the set-up of a web service account in the Business Service Portal, which is possible free of charge. The web service provides the master numbers for all legal entities for which the following event has occurred:

  • A report has been entered
  • A report has been registered which leads to a change of beneficial owner or adds a new document to a compliance package
  • A compliance package has been added
  • The report to a legal entity subject to reporting is entered into the register in 28 days one year, or a legal entity exempt from reporting becomes subject to reporting

The following possible functionalities can be implemented for obligated parties:

  • The data on the beneficial owners can initially be reconciled with the BORA in compliance with the due diligence obligations under professional law, and for all future changes, a specific job (internal approval/sending of customer questionnaires etc.) can be created semi-automatically based on the risk classification of the respective customer/client and assigned to the respective official in charge to carry over the changes.
  • For high-risk customers, it can also be provided that an alert is generated if there is a change in a relevant superordinate legal entity. This may be appropriate for customers classified as high risk. The relevant legal entities must be entered into and managed in the external system.

For professional party representatives the following additional functionalities can be implemented:

  • With the help of the change management service, effective deadline management can be implemented, as in case of legal entities subject to reporting the change management service informs eight weeks, and in case of legal entities exempt from reporting requirements, which become subject to reporting due to a change of shareholder, four weeks before a threat of a fine is sent.
  • Provision may be made for the professional party representative to identify relevant superordinate legal entities for reporting purposes. The law firm software can then transmit information to the official in charge when a change occurs in a relevant legal entity. The relevant legal entities must be entered into and managed in the external system.

Download of the technical documentation