September 2025 update

On 29 August, Companies House published further guidance on how to submit a request to Companies House to obtain access to trust information for an overseas entity. 

Part 3 of the Register of Overseas Entities (Protection and Trusts) (Amendment) Regulations 2025 (SI2025/231) (the Regulations) came into force on 31 August and enables applications to be made to access trust information relating to entries on the Register of Overseas Entities (ROE Register). This information, which was previously restricted from public inspection, can now be accessed by application subject to that application meeting certain requirements. Our Register of Overseas Entities: July 2025 update provides more details on the Regulations generally. 

Here we provide a summary of the new Companies House guidance. 

What options are there to apply?

Applications can be made for trust information where there is: 

• A single overseas entity – Option 1; or 
• More than one overseas entity, or where a trust member is age 17 and under – Option 2.

How much does it cost to make an application? 

It costs £55 for each overseas entity. 

What information must be provided with the application?

The application must be made on a particular form, which is available to download from a link within the guidance. In addition, if making an Option 2 application, the applicant must provide information proving it has a “legitimate interest” in obtaining the trust information (they must be investigating money laundering, tax evasion, terrorist financing or breach of sanctions). In such a case, the applicant will need to provide:

• A detailed written account explaining why they suspect that any trust is involved in money laundering, tax evasion, terrorist financing or breaching of sanctions;
• A statement that they are requesting the trust information to progress the investigation; and 
• A statement of how they are planning to use any trust information released to them. 

The applicant may also provide evidence in their written account to support their application (for example, extracts from documents or website links).

Are there circumstances in which Companies House could refuse disclosure? 

Yes. Companies House could refuse disclosure of trust information: 

• On national security grounds; 
• If the application form is incomplete, or a legitimate interest is not demonstrated where applicable; 
• Where disclosure may adversely affect an ongoing criminal investigation; and/or
• Where the trust is a pension scheme. 

Companies House may also impose conditions on any trust information they share with applicants. These conditions may restrict how an applicant can use or disclose the trust information. It is an offence if an applicant does not comply with any condition Companies House imposes.

What information will Companies House share? 

Companies House will share certain information about the trust including the name of the trust, the date on which the trust was created, the date the trust ceased to be involved with the overseas entity (if relevant), and former beneficial owners who were registrable beneficial owners because they were trustees of the trust (if relevant). 

As far as individuals are concerned, Companies House will not share the day of the month from an individual’s date of birth, an individual’s home address (unless the individual has used their home address as their correspondence address) or any information relating to an individual who has successfully applied for their details to be protected. However information that will otherwise be shared includes the individual’s name, the date they became involved in, or ceased to be involved in the trust and their role in the trust.