In brief
- A series of targeted amendments to existing legislation governing the UK's Register of Overseas Entities (the ROE) came into force on 9 July 2026.
- The most significant change is that when a member of the public applies to see protected trusts information on the ROE, they will no longer be required to state the relevant trust's name.
What is the Register of Overseas Entities and how does trust disclosure work?
Overseas entities which hold title to qualifying UK real estate are required to be registered on the ROE at Companies House. The ROE makes public "registrable beneficial owners", i.e. those with the requisite level of control over the overseas entity.
Where any registrable beneficial owner is a trustee, they must provide certain information about the trust to Companies House, including details of beneficiaries, settlors, grantors and other "interested persons". This information is not public but it is possible to apply to Companies House to access that information. Until recently, in order for an application to be granted by Companies House, it was necessary to include in the application the name of the relevant trust.
What are the key changes to the Register of Overseas Entities disclosure rules?
In practical terms, the changes alter the protection and disclosure regime in these key ways:
- Removal of requirement to state the trust's name: perhaps the most significant change is that the requirement to name a trust when applying for disclosure is removed. This will make it easier to apply to access trust information, for example, by using the name and registered number of an overseas entity that is publicly available on Companies House.
- Registrar can protect a minor's data while releasing other trust information: on the trust disclosure side, the changes address a gap whereby previously the presence of a minor in a trust structure could effectively block disclosure of all trust information. Under the new legislation, the Registrar will be able to release information relating to other trust participants while still protecting the minor's data.
- Evidence no longer required to suppress residential address from the ROE: before the changes were made, it was possible to apply to suppress a relevant individual's residential address from the ROE, provided evidence was submitted that the relevant individual lived at that address. The requirement to provide supporting evidence when applying for suppression of personal information has now been removed. The amendments may reduce the administrative burden on individuals who struggle to obtain formal evidence. A service address must still be provided as a replacement for any suppressed residential address, preserving a degree of public accountability for persons connected to active overseas entities.
A June amendment to the draft regulations first published in April corrected what appeared to be a drafting error which had narrowed the class of persons eligible to make a protection application under the third change above to registrable beneficial owners and managing officers only. Had this been retained, settlors and beneficiaries would have been excluded from that class.
What will the impact of the latest Register of Overseas Entities reforms be?
Giving members of the public the ability to access protected trusts information on the ROE at Companies House is a significant change. The other amendments made to the ROE reflect an attempt to balance privacy with transparency, easing certain procedural requirements for individuals seeking protection of their personal data, while adjusting the disclosure regime to prevent minor-related protections from being used to shield wider trust information.
How Mishcon de Reya can help
The changes to the Register of Overseas Entities may have important implications for trustees, settlors and beneficiaries. Our Private Wealth and Tax team advises clients on trust structures, transparency and disclosure obligations, helping them navigate evolving reporting requirements and protect their interests in an increasingly transparent regulatory environment.