UK Register of Overseas Entities requirements

The United Kingdom (“UK”) Government has introduced legislation that increases the transparency of overseas entities, which own land or property in the UK.

The Register of Overseas Entities (“the Register”) came into force on 1 August 2022, with a 6-month transitional period (until 31 January 2023) for all relevant entities to comply with the new registration requirements.

All non-UK legal entities owning UK land and property are recommended to undertake a review to determine whether they are in scope of the Act.

Overseas entities in scope must (1) identify their registrable beneficial owners and (2) provide the required information about them to the Register.  However, before the information can be filed on the Register, it must be independently verified.

It is important to note that the verification must be completed by an independent UK-regulated agent, that is required to be based in the UK and supervised under the UK Money Laundering, Terrorist Financing and Transfer of Funds Regulation 2017.

The deadline for all in-scope overseas entities to complete the registration is 31 January 2023.  There are significant penalties and sanctions for failing to do so.

Before the reporting deadline, these in-scope overseas entities are required to complete the below steps in order to be compliant:

  • Identify their registrable beneficial owners
  • Prepare and provide the required information
  • Verify the required information
  • Submit the required information to the UK Companies House