The Register of Overseas Entities (ROE) publishes information about certain overseas entities that own UK property, which can include offshore trusts. The ROE has been public since 2022, but names, dates of birth, nationalities and addresses were previously protected from public inspection. From 31 August 2025, anyone may apply for access to this data.
If their request for access is granted, Companies House may disclose the requested information to the applicant. However, there are two defences that may be available to prevent the disclosure of information.
Applying for protection against disclosure
Beneficial owners, managing officers and trust members (including beneficiaries, settlors and grantors) can apply for protection against the disclosure of their ROE information. Such protection may be granted if:
- there is a risk of harm or intimidation to the individual or someone living with them; or
- the individual is under 18 or lacks capacity.
Companies House will process applications within 30 days, during which time the relevant information cannot be disclosed.
The "legitimate interest" condition
A further safeguard will apply to protect against disclosure in the case of:
- bulk disclosure requests relating to multiple entities; and
- requests for information about individuals under 18.
In those cases, Companies House will only disclose such information if the applicant demonstrates that they have a “legitimate interest”. An example of a "legitimate interest" might be investigating money laundering, tax evasion, terrorist financing or sanctions breaches.
The "legitimate interest" condition applies where the disclosure application relates to a minor child, but not where it relates to an individual lacking capacity. The effect is that information about individuals lacking capacity is more vulnerable to disclosure, which makes it all the more important to apply for the protection of that information as described above.
Precautions against disclosure
If you are worried that your data could be subject to a disclosure application, there are precautionary actions you can take, as follows:
- Submit a protection application.
- Consider renaming your overseas trust to avoid easy identification. For example, you could use your initials instead of your full name, or you could use an unconnected abstract word.
- Replace any residential addresses on the ROE with a service or principal office address. Then, even if information is disclosed, the applicant will not have the home addresses of those parties.