Why Do We Need a Register of Overseas Entities?

The principal objective of the Register of Overseas Entities (ROE) is to provide greater transparency around UK property owned by overseas entities.

An overseas entity is classed as a company or organisation who is governed by laws outside of the UK. Overseas entities can legitimately purchase and sell property or land in the UK but the previous lack of transparency around the identity of ownership had made the UK property market a target for money laundering and other criminal activity.

On 1 August 2022, the ROE was introduced by the UK government to strengthen the laws around overseas entity ownership. The new register forms part of the Economic Crime (Transparency and Enforcement) Act 2022, which is essentially new legislation that has been launched to help combat money laundering.

Prior to the introduction of the ROE, non-UK owners of UK property or land could be hidden by using a complex company structure such as a trust, without needing to identify who had control of the asset.

Under the requirements of the Economic Crime (Transparency and Enforcement) Act 2022, the beneficial owner must be identified for overseas entities on the ROE, which is operated by Companies House.

The overseas entity must provide information about the beneficial owners, including name, date of birth and residential address. This information must be updated on an annual basis.

Who must register on the ROE?

The following entities must register on the ROE:

• Overseas entities that acquire UK land or property after 5 September 2022.
• Overseas entities that currently own land or property purchased in England or Wales on or after 1 January 1999.
• Overseas entities that currently own land or property purchased in Scotland on or after 8 December 2014.
• Overseas entities that disposed of UK property between 28 February 2022 and 31 January 2023.

What are the penalties for non-compliance with ROE filing requirements?

If any entity is found to be non-compliant, they can face fines of up to £2,500 per day and in some cases, they could be handed a prison sentence of up to five years. Restrictions on buying, selling and transferring property and land in the UK may also be applied to non-compliant entities.

ROE compliance services

You are not able to submit a registration without an authorised agent who has been approved by Companies House. As an authorised agent for verifying registration for ROE, ProSec can verify your information provided for ROE.

Contact the ProSec team for expert support and advice for fulfilling the legal responsibilities for identifying beneficial owners on the Register of Overseas Entities.