In February 2025, the Register of Overseas Entities (Protection and Trusts) (Amendments) Regulations were approved by the UK parliament. These Regulations enable Companies House to grant, upon application, access to trust information that was previously restricted.

Many of the provisions have already entered into force, but key changes will apply from 31 August 2025. The Department for Business and Trade asked STEP to review the guidance for the Registration of Overseas Entities to ensure clarity on the information required in relation to trusts.

Key changes to the protection regime

The Regulations include two main changes to the protection regime for the Register of Overseas Entities (ROE):

(1) The category of persons eligible to have their information protected from public disclosure is wider. It now includes trust beneficiaries and settlors.

(2) The category of situations in which an application for protection can be made is wider. Previously this consisted of parties at risk of harm or intimidation, or their residential address being on the ROE. This group now includes persons under the age of 18 and those who lack mental capacity. Companies House have clarified that these criteria are sufficient. Applicants need not provide evidence of risk of harm or intimidation in addition to these conditions.

Without this protection, the ‘legitimate interest’ condition will apply. Companies House will be able to disclose information about a person under the age of 18 if they deem there to be a ‘legitimate interest’ in disclosure – for example, relating to a money laundering investigation.

Apply now before 31 August 2025

The new protection regime has entered into force. Public access to trust information has been staggered to enter into force on 31 August 2025, meaning applicants have until then to apply for protection. Companies House has published guidance on how to apply for protection. It involves a paper application and a fee of GBP100 per person on behalf of whom protection is sought. Applications will take at least 30 days to process but could take up to a year. Relevant information will be protected from the public during this time.

Beneficial owners or trust managers who meet the relevant criteria should apply for protection to prevent the disclosure of personal information sooner rather than later.

Useful links

• UK Parliament: Register of Overseas Entities (Protection and Trusts) (Amendment) Regulations 2025 – Statutory Instruments
• Companies House: Apply to protect your details on the Register of Overseas Entities
• Department for Business and Trade: Guidance for the Registration of Overseas Entities on the UK Register of Overseas Entities
• Tax Journal: Update on the Register of Overseas Entities
• Mishcon de Reya: Offshore trusts holding UK land – trusts information to be available on application

Kishan Rana, Policy Executive at STEP