Ever since the register was created in August 2022, overseas entities that own UK property have had to provide information about their beneficial owners. Where the beneficial owner is the trustee of a trust, the overseas entity must also provide certain information about that trust. Until now, that information has been withheld from public view where the individual or legal entity is the trustee of a trust, although it was available to HMRC and other authorities.
Now, under regulation 4 of the Register of Overseas Entities (Protection and Trusts) (Amendment) Regulations 2025, enacted earlier in 2025, members of the public can apply to Companies House for disclosure of the information. With the coming into force of this regulation, Companies House has issued detailed new guidance on how to submit such requests, for a fee of GBP55 per overseas entity.
There are two options available, depending on the sensitivity of the information concerned. The first option is used when requesting information about a trust (or trusts) associated with a single overseas entity. The applicant does not need to demonstrate any reason for wanting to see the information; however, they must provide the names of the overseas entity and the trusts, as well as the entity's identity number, which is available on the Companies House register. If applying on behalf of an employer, the applicant must also supply their employer's name and address.
Companies House will then check whether the trust information for the overseas entity contains any details relating to a trust member aged under 18. If so, the application will be rejected, in order to protect the privacy of minor beneficiaries.
If this route fails, or the applicant wants trust information relating to several overseas entities, the second option must be used. The applicant must complete the same form but must also demonstrate a 'legitimate interest' in obtaining the trust information and what they want to use it for. They must provide information to show that they are investigating money laundering, tax evasion, terrorist financing or sanctions breaches, along with a 'detailed written account' explaining why they suspect that any trust is involved in these offences.
Companies House will release the information only if these conditions are satisfied. It undertakes to provide an answer within five days, although it may impose conditions on the use or further disclosure of the information.
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