Distinguish a legal entity from an individual in officers endpoint?

API Question
#1

Good afternoon!
Can the same officer be a legal entity in one company and an individual in another?
How can i distinguish legal entity and individual? By officer_role?
Or i jusn can use date_of_birth field? For example, in individual entity date_of_birth is always filled, but in legal entity it’s aways empty?

#2

Part 1) When you say “officers endpoint” and mention “legal entity” vs. “individual” do you mean a company / corporate entity vs. individual (natural person)?

Note: there are legal persons (as opposed to corporations and natural persons) - which are recorded separately in data returned by calls to the PSC endpoints. (These can be “corporations sole” etc.) In the cases I have found in the Officers Endpoint these seem to be treated as corporate entities, e.g. not individuals. Here’s an example of what seems to be a legal person (the role of a bishop) in the Officers endpoint:

From: https://api.company-information.service.gov.uk/company/00142351/officers
Note - some data snipped for conciseness:

{
        "links": {
            "self": "/company/00142351/appointments/3gmLEBc2U4phPlLmKmdQDioeAiw",
            "officer": {
                "appointments": "/officers/rLKkkxQBOs89AahmvCzwqM0F3G0/appointments"
            }
        },
        "address": {
            ...
        },
        "name": "THE BISHOP OF WINCHESTER",
        "appointed_on": "2021-09-27",
        "identification": {
            "identification_type": "other-corporate-body-or-firm",
            "legal_authority": "THE CANONS AND ECCLESIASTICAL LAW OF THE CHURCH OF ENGLAND",
            "legal_form": "CORPORATE SOLE"
        },
        "officer_role": "corporate-director"
}

In that case you would be correct - the primary means we (as a user of the API) use to distinguish the two is the officer_role field. So the following would be “company / corporate” (or legal persons, as noted above):

  • corporate-director
  • corporate-llp-designated-member
  • corporate-llp-member
  • corporate-manager-of-an-eeig
  • corporate-managing-officer
  • corporate-member-of-a-management-organ
  • corporate-member-of-a-supervisory-organ
  • corporate-member-of-an-administrative-organ
  • corporate-nominee-director
  • corporate-nominee-secretary
  • corporate-secretary

The following should be natural persons / individuals:

  • director
  • llp-designated-member
  • llp-member
  • manager-of-an-eeig
  • managing-officer
  • member-of-a-management-organ
  • member-of-a-supervisory-organ
  • member-of-an-administrative-organ
  • nominee-director
  • nominee-secretary
  • secretary

I believe the following are natural persons and can only be so (up to you to check though!):

  • cic-manager
  • general-partner-in-a-limited-partnership
  • judicial-factor
  • limited-partner-in-a-limited-partnership
  • person-authorised-to-accept
  • person-authorised-to-represent
  • person-authorised-to-represent-and-accept
  • receiver-and-manager

Using the date of birth field as an indicator would seem reasonable but I believe it may only be legally required for directors. It specifically is not required for secretaries (see e.g. Companies House info on personal information).

For corporate officers (including legal persons) you may also find the identification member with useful information like company number / reference. I would exercise caution here as I’m not certain it is a required field and at any rate doesn’t seem to be validated by Companies House (not even for UK companies - of course foreign registrations will have their own formats etc.)

Part 2) when you say “Can the same officer be a legal entity in one company and an individual in another?” again I’m not quite sure what you mean. If there is an individual (natural person) then they will always be recorded as an individual whatever company they are an officer of. If the company is a corporate director of more than one company it will be recorded as a company wherever it is an officer.

What you may find is that there may be multiple IDs for what you suspect or know to be the same person or entity. I can’t recall the exact circumstances where this happens (search this forum, I think it’s come up here). However someone could be registered as an officer of one company then registered as an officer of a different company with a different address / variation of their name (or possibly even an incorrect date of birth) - that might mean they were allocated a different ID?

I’m also not sure about the case of registered-overseas-entity-corporate-managing-officer value in the data from the Officers API. I have not yet seen one of these; certainly all Registered Overseas Entities (company numbers starting OE) I’ve seen have no officers, only PSCs.