Insights

Significant changes regarding the protection and access to trust data on the Register of Overseas Entities took effect from 28 February 2025. These changes aim to balance transparency with safeguarding sensitive information.

Protection of Trust Data – Starting 28 February 2025

An application can now be made to protect trust data if there is a risk of harm or intimidation to any trust members (beneficiaries, settlors, grantors, or interested parties). Protection can also be requested if acting on behalf of a trust member who is a minor or lacks mental capacity.

What’s required to make this application?

• A £100 application fee (refundable if your application is rejected).
• Full details of the risk of harm, along with supporting evidence.
• Applications should be submitted before 31 August 2025 to ensure timely protection.

Access to Trust Information – Starting 31 August 2025

From 31 August 2025, trust data will be accessible on request. However, there are strict conditions in place. Access will only be granted for purposes such as:

• Investigating money laundering
• Investigating terrorist financing
• Addressing tax evasion
• Ensuring compliance with UK sanctions

Requests will require details of the applicant, their employer, and the trust. A legitimate interest test will apply, especially for information involving minors or multiple trusts.

Keeping Information Up to Date

It’s crucial to ensure that all information on the Register of Overseas Entities, including trust-related data, is accurate. Any changes or corrections should be made in the next update statement.