From 1 September 2025, individuals will be able to request access to trust information contained in the UK’s Register of Overseas Entities that is not otherwise available to the public.
Since its introduction in August 2022, the UK Register of Overseas Entities has required overseas companies owning property in the UK to disclose details of their beneficial owners. Where a trust is involved, additional information about that trust must also be provided.
Until recently, this trust-related information was restricted from public access and available only to HMRC and other authorities. However, this has now changed with the implementation of the Register of Overseas Entities (Protection and Trusts) (Amendment) Regulations 2025, which came into force earlier this year.
Public Access to Trust Information
Under the new rules, members of the public can now apply to Companies House to obtain trust-related information connected to an overseas entity. A new application process has been introduced, with a fee of £55 for each overseas entity.
There are two application routes, depending on the type of information requested and the purpose of the application:
Option 1. Apply to access trust information for a single overseas entity (Standard Applications)
This option allows applicants to request information about a trust linked to a single overseas entity.
- No justification is required for the request.
- Applicants must provide the overseas entity’s name, its Companies House ID number, and the trust’s name.
- If applying on behalf of an employer, the employer’s name and address must also be included.
Important restriction: If the trust includes members under the age of 18, Companies House will reject the application to safeguard minors’ privacy.
Option 2. Legitimate Interest Applications
If the request involves multiple overseas entities, or if the “standard route” is unsuccessful, applicants must demonstrate a legitimate interest in obtaining this trust information. This requires:
- A detailed explanation showing that the request relates to investigations into money laundering, tax evasion, terrorist financing, or breaching of sanctions imposed by regulations under the Sanctions and Anti-Money Laundering Act 2018.
- A written account of the suspected link between the trust and these offences.
Companies House reviews these applications carefully and provides a decision within five working days. It may also impose conditions on how the disclosed information can be used.
Information That May Be Disclosed
Where disclosure is permitted, Companies House may release details such as:
- Trust name, creation date, and (if relevant) the date the trust ceased to be involved with the overseas entity.
- Names of current and former trustees and beneficial owners.
- Personal details of individuals involved (including name, month and year of birth, nationality, correspondence or service address, role in the trust, and relevant dates of involvement).
- For corporate trustees (rather that individuals), information on legal form and governing law.
However, protected information will never be disclosed. This applies to individuals who have successfully applied for their details to be withheld due to risks of harm, intimidation, or incapacity. Applications for this protection require a £400 fee.
What This Means Going Forward
The amendment marks a significant shift toward greater transparency in the UK’s property ownership framework. By making trust information more accessible to the public, the government aims to strengthen its fight against financial crime while still balancing the need to protect vulnerable individuals.
Sources
The information provided in this article is of a purely general nature and is not a substitute for specific advice that may be requested here.
