A British Columbia private company has to keep a transparency register of its significant individuals. That duty has been in force since 1 October 2020. It lives in Part 4.1 of the Business Corporations Act, S.B.C. 2002, c. 57 (the BCBCA). It is not an Ontario individuals-with-significant-control register, it is not a federal ISC filing with Corporations Canada, and it is not a public search on BC Registries.
The Province's current pages are blunt about where the register sits: at the company's records office, with the other corporate records. There is no requirement to file it with government. The public does not get it. A buyer's lawyer who asks for the minute book and finds no transparency register is not being fussy. The company was supposed to have one.
This article uses the official BCBCA text for Part 4.1 (ss. 119.2, 119.5, 119.61) and the Province of British Columbia's transparency-register guidance as those pages stood in August 2026. It is not a B.C. minute-book guide. For the records the BCBCA already requires you to keep, start with What Is a Corporate Minute Book?. Do not copy Ontario's ISC rules, or a six-month fiscal-year meeting deadline, onto a B.C. company. Those are different statutes.
MinuteKeep is for companies that are already incorporated. It does not incorporate you and it does not file with BC Registries.
What a B.C. transparency register actually is
Section 119.2(1): a private company must take reasonable steps to maintain a transparency register. The Province describes it as a list of information on the company's significant individuals, the natural persons who own or control the company, directly or indirectly.
It is a company record. It is not a BC Registries filing. It is not the central securities register, and it is not the minute book. Those records sit beside it at the records office. Mixing them up, or treating a share register as a substitute, is how the file goes incomplete.
B.C. uses the phrase "transparency register." Other Canadian statutes use "individuals with significant control." The labels are cousins. The rules are not interchangeable. The federal and Ontario ISC explainer is a different stack. Alberta has no equivalent private register inside the book. B.C. does.
Who has to keep one
The Province's current page: as of 1 October 2020, private companies in B.C. must create and maintain a transparency register. Legal entities that are not BCBCA companies, including B.C. societies and cooperatives, are not under this duty. Extra-provincial companies registered to do business in B.C. but incorporated elsewhere follow their home statute, not this B.C. register. Public companies, and companies listed on a stock exchange, are excluded.
The Province also lists these exclusions (details in the Business Corporations Regulation):
- wholly-owned subsidiaries of a public corporation
- trust companies and insurance companies as defined in the Financial Institution Act
- government corporations as defined in the Financial Administration Act
- wholly-owned subsidiaries of a special-act corporation
- companies incorporated or wholly owned by a municipality or regional district
- companies that operate an independent school in British Columbia
- companies converted under the School Act
- companies wholly owned by one or more Indigenous nations
If you are a private B.C. company and you are not on that list, you keep the register.
Who is a significant individual
The Province's how-to page is the working start. The legislation is the true source of the definition. Do not treat a blog post, including this one, as a substitute for Part 4.1.
Begin with two records the company already has to keep: the central securities register (s. 111) and the articles (s. 12). Both are internal. Neither is filed with government. Look for individuals who have:
- a direct or indirect interest in a significant number of shares (25% of the shares or 25% of the votes), or
- rights to elect, appoint, or remove a majority of the directors.
Also look for individuals who are related to one another or who appear to be acting in concert. Their interests or rights are added together.
If the central securities register or the articles show another corporation, partnership, trust, agent, or personal or other legal representative as the shareholder or rightsholder, the indirect-control rules apply. You look through that entity. A shareholders' agreement that creates extra rights or restrictions has to be read as well.
For a typical owner-managed or family-run company, the Province's how-to says the significant individuals are the owner-manager or the family members who are the shareholders. Listing yourself and any other shareholders is how that structure usually satisfies the register. A more complex holding-company chain is a different exercise.
Once you determine that someone is a significant individual, you contact that person and request the required information. The significant individual is required to provide it. Shareholders have a duty, on the Province's current page, to take reasonable steps to gather requested information and send it to the company promptly.
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The Province's current list, for every significant individual:
- full name, date of birth, and last known address
- whether they are a Canadian citizen or permanent resident of Canada
- if they are not, every country or state of which they are a citizen
- whether they are resident in Canada for the purposes of the Income Tax Act (Canada)
- the date they became, or ceased to be, a significant individual
- a description of how they are a significant individual
If the significant individual does not provide the information when asked, record as much as you can and the steps you took to get it. The same applies if you cannot obtain or confirm information from shareholders on set-up or on an update: record the reasonable steps.
Do not paste a social insurance number, an Ontario 15-day ISC clock, or a federal Corporations Canada filing into this document. Those are not the B.C. current-law list.
Where it lives, and who may see it
Section 119.5(1): subject to subsection (2), a private company must keep its transparency register at its records office. Subsection (2) allows it to be kept elsewhere so long as it is available for inspection and copying at the records office by computer terminal or other electronic technology.
The Province's how-to: keep it at the records office with the other corporate records, the articles, the central securities register, and the meeting minutes. There is no requirement to file the transparency register with government.
Section 119.61: the person who maintains the records office must allow an inspecting official, or a director of the company, to inspect the register, and must not allow anyone else to inspect it. The Province's current page names the officials entitled to inspect:
- current directors of the company
- a police force in B.C.
- the Royal Canadian Mounted Police
- the tax authority of B.C.
- the Canada Revenue Agency
- the British Columbia Securities Commission
- the BC Financial Services Authority
- the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
- the Law Society of British Columbia
Inspecting officials must identify themselves. If anyone else asks for a copy, you do not give it to them.
Inspection hours on the Province's page: 9 a.m. to 4 p.m., Monday through Friday, except holidays. The articles may narrow those hours, but the register must still be open for inspection for at least two consecutive hours on each of those days. A copying fee may be set in the articles. It must not exceed $0.50 per page.
The 2023 amendments that would have private companies file a transparency register with the registrar are not in force on the Province's current pages. Those pages still say: do not file it with government. This article describes the duty as it stands, not a future public registry.
Keeping it current
The Province's current page: update the transparency register within 30 days of receiving new or different information. That is a B.C. clock. It is not Ontario's 15-day ISC update rule, and it is not a six-month fiscal-year meeting rule. Do not import either.
If shareholdings change, if a holding company in the chain changes hands, or if someone ceases to be a significant individual, the register has to catch up once you have the information. A register last touched in 2020 is not a maintained register under section 119.2.
How it sits beside the minute book
The transparency register is one record. It is not the book.
The BCBCA still requires a records office, articles, a central securities register, and minutes of meetings and resolutions. Those are the documents people mean when they say "minute book." The transparency register sits with them. It answers a different question: who actually owns or controls the company, once you look through nominees and holding companies.
A complete central securities register does not excuse a missing transparency register. A complete transparency register does not excuse missing minutes. A buyer, a lender, or an inspecting official will ask for both.
If you are reconstructing the rest of the B.C. book, the Ontario, federal, Quebec, and Alberta guides are other statutes. Use them for contrast, not as a template. Alberta, in particular, has no private ISC-style register inside the book. B.C. does.
Transparency register checklist
- Confirm you are a private B.C. company and not on the Province's exclusion list.
- Pull the central securities register (s. 111) and the articles (s. 12). Read any shareholders' agreement.
- Identify individuals with 25% of the shares or 25% of the votes, or rights to elect, appoint, or remove a majority of directors, including indirect and joint holdings.
- Request the prescribed particulars from each significant individual. Record the steps if the information does not come back.
- Enter the six items the Province lists for every significant individual.
- Keep the register at the records office, or make it inspectable there electronically (s. 119.5).
- Do not file it with BC Registries. Do not hand it to anyone who is not a current director or a named inspecting official (s. 119.61).
- Update it within 30 days of receiving new or different information.
- Keep it inspectable 9 a.m. to 4 p.m. Monday to Friday except holidays, or at least two consecutive hours on each of those days if the articles narrow the window.
Frequently asked questions
Is a B.C. transparency register the same as an Ontario ISC register?
No. B.C. uses "transparency register." Ontario and the CBCA use "individuals with significant control." The 25% idea is similar. The filing rules, the clocks, and the inspectors are not. Do not paste Ontario's private-register practice, or a federal filing with Corporations Canada, onto a B.C. company. See the ISC explainer for that other stack.
Do I file the transparency register with BC Registries?
No. The Province's current how-to: there is no requirement to file the transparency register with government. Keep it at the records office. A public registry contemplated by later amendments is not the current duty on those pages.
Can it be kept electronically?
Yes, if section 119.5(2) is met: it may be kept somewhere other than the records office so long as it is available for inspection and copying at the records office by computer terminal or other electronic technology. A file that lives only on a laptop that is not at the records office during inspection hours is not what that subsection contemplates.
Who may inspect it?
Current directors, and the inspecting officials the Province names (B.C. police, RCMP, B.C. tax authority, CRA, BC Securities Commission, BCFSA, FINTRAC, Law Society of B.C.). Inspecting officials must identify themselves. Anyone else who asks does not get a copy.
What if we are a one-person company?
The Province's how-to: in most owner-managed companies, the significant individuals are the owner-manager or the family members who are the shareholders. Listing yourself, and any other shareholders, is how that structure usually satisfies the register. You still keep the record. You still update it.
Does MinuteKeep incorporate a B.C. company or file the register?
No. MinuteKeep is for companies that are already incorporated. It does not incorporate you. It does not file with BC Registries. The transparency register stays a company record at the records office.
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This article is general information, not legal advice. It is not a substitute for the BCBCA or for the Province's current transparency-register pages.