[UK] Time to update: further changes to the Register of Overseas Entities coming into effect this summer

Overseas entities that own property in the UK will, by now, be familiar with the registration and disclosure regime implemented by the Economic Crime (Transparency and Enforcement) Act 2022 and bolstered by the Economic Crime and Corporate Transparency Act 2023.  However, two further changes to the register of overseas entities regime will come into force this summer:

1. First, is the requirement for those overseas entities that were required to register by 31 January 2023 to provide retrospective information in respect of the ownership of the entity for the pre-registration period. The pre-registration period being 28 February 2022 to 31 January 2023, or if earlier the date of registration. The relevant overseas entities will need to disclose changes (if any) to their registerable beneficial owners and trust information (including beneficiaries) during the relevant period to Companies House as part of the annual update.
   
   Companies House have published that the requirement begins from 31 July (though implementation regulations have not yet been published). However,  where the overseas entity is due to provide its annual update before 31 October 2025, the retrospective reporting can be delayed until the following year's update.    
    
2. Secondly, from 31 August 2025, anyone will be able to apply to the Registrar of Companies House for the disclosure of trust information where trust forms part of the beneficial ownership structure of the overseas entity. This will include information such as the beneficiaries and settlors of a trust. This change is designed to increase transparency around trust arrangements, allowing for greater scrutiny of the individuals or entities benefiting from such trusts. There are applications that can be made to prevent disclosure of relevant protected trusts information, but these generally relate to minors or persons at risk of violence or intimidation.
   
   An applicant is required to provide the name of the trust as part of this application (which is generally not publicly available information) and the Registrar may refuse an application for the disclosure of trust information where it has not been provided, as well as in some other circumstances. Further, if an applicant is making a 'bulk' application relating to multiple trusts or a request that involve minors (i.e. as the beneficiaries), they must additionally provide evidence that they have a legitimate interest in the disclosure (such as the investigation of money laundering, tax evasion, terrorist financing and sanctions breaches).

Please refer to our register of overseas entities briefing for further detail on these changes and those yet to come.

Outside of the register of overseas entities, provisions of the Economic Crime and Corporate Transparency Act 2023 are also being implemented in relation to the new identity verification regime. All new and existing UK company directors, people with significant control and those filing information with Companies House will need to have their identity verified. This can be done directly with Companies House or through an ‘authorised corporate service provider' (ACSP).

ACSPs have been able to register since 18 March 2025 and voluntary verification has been open since 8 April 2025. Identity verification will become mandatory for all directors and PSCs on new incorporations in Autumn 2025 and a 12-month transition period will begin for existing companies.

See our IDV snapshot here.