Upcoming changes to trust data access on the UK Register of Overseas Entities

There are significant changes to the access and protection of trust data held on the UK Register of Overseas Entities (ROE), which will take effect throughout 2025.

Protection of trust data

As of 28 February 2025, eligible individuals can apply to protect their trust-related data from public disclosure. If you or a trust member meet the necessary criteria, we recommend submitting your application well in advance of 31 August 2025, when trust data will become accessible upon request.

Applications for protection should be made if a trust member or someone residing with them is at risk of harm or intimidation should their details be disclosed. Trust members include:

• Beneficiaries
• Settlors
• Grantors
• Any other interested parties

Applicants must provide detailed information about the risk posed and submit supporting evidence. Those with the legal authority to act on behalf of a trust member—such as minors (aged 17 and under) or individuals lacking capacity under Section 2 of the Mental Capacity Act 2005—are also eligible to apply.

To complete the form, applicants will need to provide:

• The overseas entity (OE) name, address, and reference number (if available)
• Applicant’s details
• Details of the trust members at risk
• Evidence supporting the risk claim

A fee of £100 per application is required, which will be refunded if the application is denied. Please note that a Harneys Fiduciary fee will also be applicable.

Access to trust information

Effective 31 August 2025, trust data on the ROE will be available upon request, following new legislative requirements. Companies House may grant access to third parties in limited circumstances, provided the applicant meets specific criteria.

Applicants requesting trust information must provide:

• Their full name and contact details
• Job title and employer’s name and address
• The name of the overseas entity and its OE reference number
• The name of the trust

For requests related to minors or multiple trusts, a legitimate interest test will be applied. Information will only be shared if the request relates to an investigation into:

• Money laundering
• Terrorist financing
• Tax evasion
• Avoiding UK sanctions regime

Companies House may impose conditions on the use or further disclosure of any trust data provided.

Keeping your information updated

Making sure that trust-related data on the ROE is accurate and current is essential. Any updates or corrections should be made in the next scheduled update statement to maintain compliance.

For further details on how to apply for data protection or request trust information, please contact your usual Harneys Fiduciary representative or visit the UK government website.