Article 2.6.6 Reporting and Transparency

(a) Record-Keeping Obligations:

Every legal entity shall maintain accurate, verifiable, and up-to-date digital records accessible through the ICT digital governance infrastructure. At a minimum, these records shall include:

(i) Foundational documents and amendments;

(ii) Registered office address and designated compliance contact; and

(iii) Financial statements, where applicable under this ICT Code;

(b) Periodic Reporting Requirements:

Entities shall comply with periodic reporting requirements as prescribed by the Operator or Companies Registrar. These shall include, but are not limited to:

(i) Annual confirmation and financial statements;

(ii) Notification of changes in beneficial ownership, controlling interests, or key management;

(iii) Amendments to the entity’s name, legal form, or primary business activity;

(iv) Reports on mergers, conversions, dissolutions, or continuation actions; and

(v) Any event materially affecting stakeholders, creditors, or the public interest.

(c) Tiered Disclosure Regime:

A proportionate disclosure framework shall apply based on the entity’s characteristics, as provided in Article 2.6.7.

(d) Enhanced Transparency Obligations for Public-Facing Entities:

Entities engaged in public-interest functions including management of critical infrastructure or public service provision may be subject to additional obligations, including:

(i) Disclosure of executive compensation and material related-party transactions;

(ii) Submission of annual impact assessments or public benefit reports; and/or

(iii) Participation in public review, stakeholder consultation, or audit processes.

(e) Digital Access and Interoperability:

All filings, registers, and disclosures shall be submitted through the ICT City App or compatible ICT interfaces, and shall:

(i) Be machine-readable and structured according to open digital standards;

(ii) Enable access by authorised third parties (e.g., creditors, courts, auditors) via secure digital protocols;

(iii) Be stored on tamper-evident infrastructure, with audit trails available for verification.

(f) Privacy, Confidentiality, and Due Process:

All disclosure and record-keeping requirements shall be implemented in a manner consistent with:

(g) ICT privacy laws and data protection standards set out in Part 3 of this ICT Code;

(i) Legitimate expectations of commercial confidentiality;

(ii) Procedural fairness, including right to correct, appeal, or redact sensitive information;

(h) Compliance and Sanctions:

(i) Failure to comply with reporting and transparency requirements may result in:

(ii) Initial warnings from the Operator, Companies Registrar or related body appointed by the Operator;

(iii) Suspension of registration status or more severe regulatory warnings;

(iv) Fiscal penalties proportionate to the entity’s size and harm caused;

(v) Disqualification of responsible officers from holding fiduciary positions within ICT entities;

(vi) In limited severe cases, Revocation of entity ICT operating licence.

(vii) Each such sanction may be subject to review by the ICT Court.