ARTICLE
18 June 2026

UK Beneficial Ownership Registers: June 2026 Developments

M
Macfarlanes LLP

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The UK government has introduced significant amendments to both the Register of Overseas Entities and Trust Registration Service regimes, affecting how trust information is accessed and who must register.
United Kingdom Corporate/Commercial Law
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We wrote previously (in May 2026) about the publication earlier this year of draft regulations which, if passed, would amend both the UK’s Register of Overseas Entities and Trust Registration Service regimes.

In both cases, the effect of the regulations would (in part) be to widen access to trust information recorded on these registers, although a couple of more helpful changes were to be introduced too. June 2026 has brought with it developments in respect of both sets of draft regulations, which we discuss further below.

Register of Overseas Entities (ROE)

In our previous article, we discussed the publication (in April 2026) of draft regulations – The Register of Overseas Entities (Protection and Trusts) and Limited Liability Partnerships (Application of Company Law) (Amendment) Regulations 2026 - which, if approved, would have the effect of amending the ROE regime, including widening access to trust information. Notably, members of the public would be able to apply to access trust information held on the ROE without naming the trust itself (currently, such identification is required).

We noted in that article that the draft regulations appeared to narrow the class of persons in relation to whom an ROE protection application can be made. Such an application can currently be made by any individual (including trust settlors and beneficiaries) whose protected information is capable of being disclosed on the ROE, to suppress that information from public disclosure. However, the draft regulations attempted to limit the class of potential applicants, so that it would only have been registrable beneficial owners or managing officers of an overseas entity in respect of whom a protection application could be made (meaning that, for example, trust settlors and beneficiaries would not be eligible). The amendment appeared to be unintentional since it was at odds with other areas of the legislation and reforms of the ROE protection regime introduced in 2025.

In May 2026, the Government noted that it had withdrawn the above draft regulations. These have now been replaced with an amended set of draft regulations (and explanatory memorandum), of the same title and in the same material form, albeit the unintended consequence regarding who is able to make an ROE protection application has now been removed.

This means that, assuming the new draft regulations are approved, the previously reported changes, including regarding the widening of access to ROE trust information, will still be going ahead. However, no changes will be made to the class of individuals who are able to make a protection application and the current position in this regard is preserved.

The new draft regulations have been laid before Parliament (on 1 June 2026) and will come into force on the day after they are made (i.e. signed by a Minister). We will report on this when it happens.

Trust Registration Service (TRS)

We wrote in our earlier article about draft regulations, published in March 2026 (superseding earlier draft regulations published in September 2025), which, if passed, would introduce several changes to the TRS regime. These include, notably, a de minimis exemption for smaller trusts and the widening of registration and data-sharing requirements for non-UK trusts holding UK land: in particular, the extension of the TRS registration requirement to include all non-UK express trusts that hold an interest in UK land acquired before 6 October 2020 (for a full description of the changes to be introduced, see our article).

The regulations (in materially the same form as the March 2026 draft, and with an accompanying explanatory memorandum) have now been ‘made’ (i.e. become law) as of 9 June 2026, and the TRS provisions will come into force on 30 June 2026 (i.e. 21 days after the day on which the regulations were made).

By way of reminder, this means that from 30 June 2026, existing trusts that meet the de minimis requirement may now deregister from the TRS. Additionally, non-UK trusts holding UK land acquired pre-6 October 2020 have until 1 September 2027 to register on the TRS, so the requirement is not immediate and still gives affected trusts some time to organise their affairs.

Macfarlanes is a pre-eminent law firm advising a global client base across Private Capital, Private Wealth, M&A and Disputes.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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