Insights

April and June 2026 have seen significant developments in relation to the UK’s Register of Overseas Entities ("ROE") and Trust Registration Service ("TRS"), continuing the government's focus on transparency of trust ownership and control structures previously highlighted in our March 2025 update.

Although beneficial ownership disclosure is not a new concept, the combined effect of the Economic Crime and Corporate Transparency Act 2023 ("ECCTA"), the ongoing reform of Companies House and the Register of Overseas Entities ("ROE") means that businesses and private clients can expect significantly greater scrutiny of ownership and control structures.

This newsletter focuses on the recent amendments to the draft statutory instruments.

ROE

In April 2026, amendments to the ROE regime expanded access to trust-related information held on the register. Importantly, certain trust information associated with overseas entities could be accessed by members of the public without naming the trust itself (in contrast with the current situation that requires such identification). The aim of this amendment is to increase the transparency of trust arrangements connected to UK land ownership.

In June 2026, revised draft regulations relating to applications for protection from disclosure of trust information under the ROE were laid before Parliament following the withdrawal of earlier drafts that had inadvertently narrowed the categories of persons entitled to seek protection. The revised draft restores the intended position, allowing eligible parties to apply for protection where disclosure would give rise to a risk of serious harm or where other statutory grounds are met.

However, the June 2026 regulations do not reverse or restrict the wider access to trust information introduced by the April 2026 amendments. Rather, they are focused on the operation of the protection regime and the circumstances in which information may be withheld from disclosure.

The draft regulations are currently progressing through Parliament. If approved, they will introduce a mechanism for eligible individuals to apply to Companies House for protection from disclosure of trust information on a case-by-case basis.

TRS

Separately, The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 became law on 9 June 2026 and will come into force on 30 June 2026.

Key changes introduced by these regulations include an exemption for certain smaller trusts holding only limited assets below specified value thresholds, meaning registration may no longer be required. The regulations also extend registration requirements to certain non-UK trusts holding UK land acquired before October 2020, with transitional provisions allowing affected trusts until 1 September 2027 to comply.

The TRS remains a non-public register. Access to trust data is restricted to HMRC, law enforcement agencies, and other authorised authorities, with limited access available to persons able to demonstrate a legitimate interest in accordance with the applicable statutory framework. Unlike company registers, the TRS cannot be searched by trust name by members of the public.