May 1, 2026 Register of Overseas Entities: trust disclosure rules tightened again
When we first wrote about trust disclosure reforms for the Register of Overseas Entities (ROE) in January 2025, the direction of travel was clear: the UK government was progressively closing the gap between what overseas entities must tell Companies House and what the public can actually see. Those changes came into force in August 2025. New draft regulations published in April 2026 go further still. If you haven’t yet reviewed your position, now is a good time to do so.
What changed in August 2025
From 31 August 2025, trust information held on the ROE, including details of beneficiaries, settlors, grantors and other interested parties, became available to third parties upon application through Companies House’s Trust Disclosure Service. Previously, this information was held privately.
Exemptions exist, but they must be applied for. The three categories that qualify are:
- Minors (aged 17 and under)
- Those at risk of violence or intimidation
- Vulnerable persons
Since August 2025, we have been working with clients to file protection applications, including family offices and TCSPs acting for UHNW individuals where public disclosure raises genuine security concerns, and trustees seeking to protect the identities of minor beneficiaries. If you haven’t reviewed whether any trust members qualify, that review is overdue.
What the April 2026 draft regulations add
Three changes are proposed.
Applying will get easier for third parties. Currently, anyone applying to access trust information must provide the trust name, which isn’t publicly available, creating a practical barrier. That requirement, which drew criticism from transparency campaigners at the time, is now being removed. Once these regulations come into force, a third party will only need the overseas entity name and Companies House ID number, both publicly searchable, to make an application.
Minor beneficiaries will no longer shield other trust members. Under the 2025 rules, if a trust included a member under 18 and the applicant hadn’t established a legitimate interest in relation to that individual, the minor’s presence effectively blocked access to all other trust information. The new regulations change this: the minor’s own details remain protected where legitimate interest hasn’t been demonstrated, but all other trust information, including other beneficiaries and settlors, will be disclosed. Structures that relied on this position need to be reassessed.
Home address removal is being updated. Currently, all individuals applying to have their residential address suppressed from the public ROE must provide supporting evidence. Under the new regulations, the evidence requirement is being removed for home address applications specifically, though it remains in place for applications based on risk of violence or vulnerability. In most cases, applicants will also now be required to provide a replacement service address. The two exceptions are where the overseas entity has since been removed from the register or where the individual is no longer a beneficial owner or managing officer of that entity.
Practical Next Steps
The 2026 regulations aren’t yet law, but the pattern with ROE reform has been consistent: draft regulations pass without significant amendment. A few things are worth bearing in mind now:
- If you have trust members who may qualify for protection, minors, those with security concerns, or vulnerable persons, and haven’t yet filed a protection application, this should be a priority. Protection is not automatic and must be applied for. We have been helping clients through this process, including family offices and TCSPs acting for UHNW individuals where disclosure raises genuine security concerns.
- If your trust includes a minor beneficiary and you have assumed that their presence provides broader protection to other trust members, that assumption no longer holds once the new regulations come into force. Only the minor’s own details will be withheld; all other trust information will be disclosable. If this affects your structure, you may wish to consider if you are eligible for protection under other grounds, such as security concerns.
- If you want your residential address removed from the public ROE, the process is changing. The requirement to provide supporting evidence is being removed for home address applications, but you will now need to provide a replacement service address in most cases. Elemental can provide a service address.
If you’d like to discuss how any of this applies to your situation, please get in touch, and we would be happy to help. Visit here to find out more about our Register of Overseas Entities service.