ADR legal entity name modification

Question

In accordance with the Consumer Data Standards, the legal_entity_name for Accredited Data Recipient (ADR) is classed as immutable in the Software Statement Assertion (SSA) definitions for the Dynamic Client Registration (DCR).

However, the legal_entity_name of an ADR could change due to mergers, acquisitions or rebranding.

In this case, is it true that that the legal_entity_name for an ADR that is registered with the ACCC and Data Holders (DHS) also has to be updated to reflect this change and the previous legal_entity_name cannot be used for DCR?       

Answer

The legal_entity_name for an ADR is optional in accordance with the SSA definition for DCR, but once provided it is immutable.

Any modification to the ADR’s legal_entity_name needs to be updated with the ACCC and then through Data Holder registrations, as the value is sourced from the Register and can only change with approval from the Registrar. An example scenario where this may take place is when an ADR rebrands – the legal_entity_name could be changed to reflect new branding.

Change Log

Updated: 17 December 2024

Note: The Standards do not currently specify that the legal_entity_name value can be changed once provided. Mutability of `legal_entity_id` and `legal_entity_name` is being reconsidered and therefore a change has been proposed in Standards Issue #679 - Update SSA specification to track and discuss this issue.