Update on the UK’s Trust Registration Service and Register of Overseas Entities

Trust Registration Service

Under the current framework, a non UK trust is generally required to register on the TRS only in limited circumstances. These include where the trust directly acquires UK land on or after 6 October 2020, incurs a UK tax liability, or (where a UK resident trustee is involved) enters into an ongoing business relationship with a UK “relevant person” (for example, a solicitor, accountant, bank, estate agent or other person to whom the UK’s money laundering legislation applies).

Regulations made on 9 June 2026 introduce a significant extension to the TRS regime. In particular, non‑UK trusts that acquired an interest in UK land before 6 October 2020, and continue to hold that interest when the new rules come into force on 30 June 2026, will be brought within scope. We previously published an article on this subject in Globally Speaking October 2025. Since this article was published, we now know that affected trusts will benefit from a transitional period in which to gather the required information, with a registration deadline of 1 September 2027.

The policy emphasis on transparency is further reinforced by the TRS data‑sharing rules. Although the TRS register is not publicly searchable, information may be disclosed to those who can demonstrate a “legitimate interest”, typically linked to the investigation of financial crime; however, there is currently no data-sharing in respect of non-UK trusts holding UK land provided the trust has no UK trustees. The regulations extend the data-sharing rules so that this category of trust will be within scope for data requests going forwards. This is a material widening of transparency for offshore structures. Importantly, the data-sharing requirement is different where a trust holds a controlling interest in a “third country entity” (broadly, a non‑UK entity which is not subject to national legislation equivalent to the EU’s rules on transparency of beneficial owners). In such cases, information regarding the trust’s beneficial owners may be disclosed without the need to satisfy the “legitimate interest” test. Currently, this rule does not apply to non-UK trusts holding UK land where there are no UK trustees, but this will change when the regulations come into force at the end of this month. Therefore, while safeguards remain, the reality is that trust structures holding UK land are becoming more visible, which may raise privacy and governance concerns, particularly for high-profile families.

The compliance burden should not be underestimated. Registration requires detailed disclosure of the trust’s beneficial owners (including settlors, trustees and beneficiaries). Thereafter, trustees must ensure that the TRS record is actively kept up to date. Failures to comply may give rise to penalties.

Register of Overseas Entities

Where UK land is held through an overseas entity, trustees within the ownership chain must already engage with the ROE regime. ROE requires overseas entities to provide Companies House with details of their registrable beneficial owners as a condition of acquiring or holding UK land.

Since 31 August 2025, members of the public have been able to apply to Companies House for access to trust information recorded on the ROE in certain circumstances. We previously published articles on this subject in Globally Speaking March 2025 and October 2025.

The latest draft regulations published on 1 June 2026 go further in terms of information becoming more freely available to the public. In particular, the proposed reforms remove the requirement for an applicant to identify a trust by name when requesting disclosure. Instead, the name and identification number of the overseas entity (both publicly available via Companies House) will be sufficient; thereby removing a practical barrier to obtaining trust-related information.

The draft regulations also adopt a less restricted approach to disclosure where trusts involve minor beneficiaries. While information relating directly to minors will continue to be withheld unless a “legitimate interest” is established, other associated trust information may be disclosed without meeting that threshold. This reflects an easing of the current position, under which broader trust information would typically be withheld in such cases.

The ROE protection regime remains available, enabling applications to Companies House to withhold certain information from public disclosure. However, protection will continue to be granted only in limited circumstances. A welcome development is the streamlining of the process for removing an individual’s residential address from the public register, as evidence of actual occupation will no longer be required. In most cases, however, a replacement service address will still need to be provided.

The draft regulations are currently making their way through Parliament and will come into force on the day after they are made.

For many non-UK trusts, these reforms mark a clear transition towards a more visible and regulated environment. Early engagement with advisers will be essential to ensure compliance, consider whether any protective applications may be appropriate and to manage wider reputational and governance risks.

For further information, please contact the Wedlake Bell Private Client team or your usual adviser.

This article is for general information purposes only and does not constitute legal advice or a comprehensive statement of the law. Specific legal advice should always be sought in relation to individual circumstances.

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   • Clare Armitage

   • Partner
   • Private Client

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   • Abigail Pearson

   • Associate
   • Private Client

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