Key Developments in UK Trust Transparency: ROE and TRS Reforms in 2026

28
Jul, 2026

 The United Kingdom continues to strengthen its commitment to corporate transparency through a series of legislative reforms affecting trusts and overseas ownership structures. During 2026, important amendments to both the Register of Overseas Entities (ROE) and the Trust Registration Service (TRS) have further expanded reporting obligations while refining the balance between transparency and the protection of sensitive information. 

 These developments form part of the UK's broader strategy to combat economic crime, improve the integrity of the property market and enhance confidence in corporate ownership structures. Building upon the reforms introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA) and the ongoing modernisation of Companies House, the new measures require trustees, overseas entities and professional advisers to reassess their compliance obligations. 

 Changes to the Register of Overseas Entities 

 From April 2026, amendments to the ROE framework expanded public access to certain trust-related information recorded on the register. Previously, access to this information generally required identification of the relevant trust. Under the revised rules, specified trust information linked to overseas entities owning UK property can now be accessed without first identifying the trust by name. The objective is to enhance transparency around trust structures connected with UK real estate while supporting efforts to combat economic crime. 

 A further development followed in June 2026, when the government introduced revised draft regulations governing applications to protect trust information from public disclosure. These replaced earlier draft regulations that had unintentionally limited the categories of individuals entitled to seek protection. 

 The revised proposals restore the intended legal position by allowing eligible applicants to request that trust information be withheld where disclosure could create a genuine risk of serious harm or where other statutory conditions are satisfied. Importantly, these regulations do not reverse the broader public access introduced in April. Instead, they establish a framework enabling Companies House to consider protection requests on an individual basis where justified. 

 The draft regulations are currently progressing through Parliament and, if approved, will provide an important safeguard balancing increased transparency with the need to protect individuals in appropriate circumstances. 

 Updates to the Trust Registration Service 

 Separate changes have also been introduced to the Trust Registration Service through the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, which became law on 9 June 2026 and take effect from 30 June 2026. 

 Among the most significant amendments is the introduction of an exemption for certain low-value trusts holding assets below prescribed thresholds. Qualifying trusts may no longer be required to register, reducing the administrative burden for smaller arrangements. 

 Conversely, the regulations expand the scope of the TRS by requiring certain non-UK trusts that acquired UK land before October 2020 to register. Transitional provisions allow affected trusts until 1 September 2027 to comply with these new obligations. 

 Unlike the ROE, the TRS remains a non-public register. Information is accessible primarily to HM Revenue & Customs, law enforcement bodies and other authorised public authorities. Limited access may also be granted to applicants who can demonstrate a legitimate interest under the relevant legal framework. Members of the public cannot search the register by trust name, preserving a higher level of confidentiality than applies to company registers. 

 Looking Ahead 

 The 2026 reforms demonstrate the UK's continued focus on improving transparency while maintaining appropriate protections for sensitive information. Businesses, trustees, overseas entities and private clients should carefully assess whether the new requirements affect their reporting obligations and ensure that ownership and trust structures remain compliant with the evolving regulatory landscape. As the transparency regime continues to develop, proactive compliance will become increasingly important for organisations with UK property or trust interests. 

 

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 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.

 

 

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