Estonia: public BO data due to be withdrawn from e-äriregister — live lookup will stop yielding beneficial owners

[StephenAbbott]

Context

Companion to #22, which covers the Time Machine (SOAP history) side of the same change. This issue covers the live lookup side.

From 10 July 2026 (the AMLD6 transposition deadline) an unknown future date, Estonia's e-äriregister stops showing beneficial ownership data to unauthenticated users. Enquiries will require e-ID login (ID-card, Smart-ID, Mobile-ID or EU eID), access becomes purpose-based (competent authorities, obliged entities, legitimate interest), BO data stops being published as open-data files, and BO data is removed from the Detailed Data API in favour of a dedicated, entitlement-gated Beneficial Owners API. Background: Silva Hunt summary of the new access rules; register at ariregister.rik.ee.

Estonia has never had domestic trusts (no Estonian trust law — foundations/sihtasutus fill that niche and remain covered as legal persons), so the loss is specifically the company BO table.

How this hits OpenCheck's live lookup

The ariregister adapter's lookup path is a no-credential public scraper: it reads the company print page (GET /eng/company/{reg}/company_print_json) and parses three tables — officers, shareholders, and beneficial owners (_parse_beneficial_owners in backend/opencheck/sources/ariregister.py). map_ariregister() in backend/opencheck/bods/mapper.py turns each BO row into a BODS person statement + ownership-or-control relationship, which render as nodes/edges in the graph view.

Once the BO table is no longer served to anonymous visitors, the expected behaviour is graceful degradation: _find_table finds no matching table → beneficial_owners: [] → no BO statements → no BO nodes in the graph. Officers and shareholders are registry-card data and are unaffected.

What to do

• Verify live behaviour against a real Estonian entity (e.g. Bolt's operating company). Confirm the scraper doesn't error on whatever replaces the table — a login prompt, notice banner, or restructured page could conceivably confuse _find_table or the not-found redirect check. If the print page now errors or redirects for anonymous users entirely, the adapter needs a guard so officers/shareholders parsing still succeeds.
• Keep the parsing code. _parse_beneficial_owners is harmless when the table is absent and documents what the register used to expose. Do not wire in the new Beneficial Owners API — it requires an entitlement Estonia does not grant anonymous foreign tools, and OpenCheck's model is open data only.
• Document the coverage change in docs/sources.md: the Estonian adapter now yields officers and shareholders but no beneficial owners. Without this note, missing Estonian BO nodes will look like a bug to future readers.
• Consider whether map_ariregister()'s docstring and the adapter module docstring should note the reality after access revoked (they currently say the parser extracts "officers, shareholders, and BOs").

Notes for whoever picks this up

• Existing tests use offline HTML fixtures captured before the change, so they will keep passing regardless — only a live check shows the real post-change behaviour. Consider capturing a fresh post-change fixture for the anonymous view and adding a test pinning the graceful-degradation path.
• The adapter's stub-detection rule is: if the response URL no longer contains /eng/company/, the server redirected away (company not found). Verify the new access regime doesn't trip this for valid companies.
• No frontend changes expected: the graph simply renders whatever statements arrive.

[StephenAbbott]

Implemented in 77e7b65 (together with #22). One finding from live verification worth recording:

On the changeover morning (10 July), the anonymous print page was still serving the BO table. Bolt Technology OÜ (reg 14532901) returned HTTP 200 with officers, shareholders and a parseable beneficial-owners row, alongside a new "Authentication is required to request access" prompt and a banner announcing the Beneficial Owners Database changes. RIK appears to be rolling the restriction out through the day (or gating the dedicated BO service/open-data files/Detailed Data API first).

Because of that, graceful degradation is pinned by fixture rather than assumed: _HTML_BO_WITHDRAWN in tests/test_ariregister.py reproduces the post-change page shape (BO table replaced by the observed auth-prompt markup) with parser-level and bundle-level tests asserting beneficial_owners == [] while officers/shareholders still parse — so whenever the switch actually flips, the adapter's behaviour is already tested.

Per the issue checklist:

• ✅ Live behaviour verified on the day; the auth-prompt markup does not confuse _find_table (headers don't match) or the not-found redirect check (response stays on /eng/company/).
• ✅ Parser code kept; the entitlement-gated replacement Beneficial Owners API deliberately not wired in.
• ✅ docs/sources.md documents the coverage change ("missing Estonian BO nodes are expected, not a bug"); adapter/module docstrings updated.
• ✅ Fresh degradation fixture + tests added.

Worth a spot-check in a day or two that the live page has actually flipped and the card renders sensibly without BO nodes.

[StephenAbbott]

Dataset withdrawal notice — dataset-estonia-2026-07-04

The OpenCheck Estonia BODS dataset (2026-07-04) release has been withdrawn and its tag deleted.

The snapshot combined GLEIF LEI data with the Estonian e-Business Register's shareholders, officers and beneficial owners, built from RIK's bulk open-data files as lawfully published (CC BY 4.0) on 4 July 2026.

On 10 July 2026, Estonia withdrew open data publication of beneficial ownership data as part of its AMLD6 transposition — access is now purpose-based behind e-ID authentication (see this issue and #22). With the source publication ended, continuing to distribute the BO layer — names of natural persons — no longer has the footing it was published under, so the whole release has been taken down rather than left up in contradiction of the change.

What this does and doesn't mean:

• Withdrawn: ongoing distribution of the snapshot from this repository. Copies already downloaded are unaffected — a deleted release is not a retraction.
• Unaffected: the officers and shareholders layers remain CC BY 4.0 open data from RIK. A re-cut of the dataset without the beneficial-owner statements may be published in future if there's interest (backend/scripts/sweep_estonia.py minus the BO mapping). One erratum for any re-cut: the registry-code join scheme was described as EE-KMKR in the release notes; the correct scheme is EE-ARIREGISTER (EE-KMKR is the VAT number).
• Live lookups: OpenCheck's Estonian adapter continues to serve officers and shareholders; beneficial owners ended at 9 July 2026 data (commit 77e7b65).

[StephenAbbott]

Reopening — Estonia postponed the restriction on its start date (see #22 for the full revert notes).

The Ministry of Finance announced the postponement on 10 July itself: current public access rules remain, no new date announced — https://news.err.ee/1610074816/estonia-s-regulation-to-hide-beneficial-owners-postponed. This explains the observation recorded above: the BO table was still being served on the changeover morning because the changeover never happened.

Status after the revert (a277aec):

• Live lookups continue to parse and map Estonian beneficial owners — nothing to do.
• The _HTML_BO_WITHDRAWN degradation fixture + tests are kept: they pin the scraper's behaviour against the auth-prompt page shape observed during the aborted changeover, so whenever the new date lands the graceful degradation is already tested.
• eu_bo_access.json no longer carries an EE entry (the "restricted from 2026-07-10" notice had become false); re-add it with the new restricted_from date once announced. The RIK legitimate-interest guidance link for that entry is https://abiinfo.rik.ee/en/node/366/.
• The withdrawn dataset-estonia-2026-07-04 release is a separate decision — RIK's bulk BO open data presumably continues under the current rules, so a re-release (or a fresh cut) is defensible again if wanted.

Blocked on Estonia announcing the new effective date. Watch https://news.err.ee/keyword/41169487 (ERR's beneficial-owners tag) and RIK announcements.