The UK is once again tightening its corporate transparency rules. The Register of Overseas Entities (Protection and Trusts) (Amendment) Regulations 2025 introduce new obligations for overseas entities, particularly those involving trusts.
These changes mark a significant shift towards greater scrutiny, with new disclosure requirements and enhanced safeguards.
So, what’s changing, who’s affected, and what do you need to do to stay compliant? Here’s a breakdown of the key updates.
What’s Changing?
The amendments make two major updates to the Register of Overseas Entities (ROE) framework under the Economic Crime (Transparency and Enforcement) Act 2022 (ECTEA 2022) and the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).
First, the rules for protecting personal information are expanding. Individuals under 18 and those lacking mental capacity will now have stronger protections against public disclosure. This means applications to shield their details will be easier to submit, provided proper authorisation is in place.
Second, trust-related data is now subject to wider disclosure. Any individual can apply to access trust information linked to overseas entities, but additional conditions will apply. If the request involves multiple entities or minors, the applicant must demonstrate a legitimate interest—such as investigating money laundering, tax evasion, or sanctions breaches. The Registrar also has the power to reject requests that could compromise national security or ongoing investigations.
Who’s Affected?
The changes primarily impact overseas entities holding UK property and those involved in trusts. If an overseas entity is structured through a trust, there will be stricter scrutiny of its beneficial owners. Additionally, legal professionals, financial institutions, and compliance teams handling trust structures should be aware of the new access conditions for trust data.
When Do These Changes Take Effect?
The regulations come into force in two phases:
Most of the new rules, including personal information protections, will be effective from 28 February 2025.
The trust disclosure provisions will take effect later, from 31 August 2025.
What Should You Do Next?
With these amendments, overseas entities and their advisors should review their structures and ensure compliance with the evolving transparency framework. If trusts are involved, entities should prepare for potential disclosure requests and understand the new protection application process for sensitive data.
These changes reflect the UK government’s continued effort to close loopholes in corporate transparency and financial crime prevention. With enforcement powers expanding, now is the time to assess risks and take proactive steps to align with the new regulations.
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