Trust information on the overseas entities register got easier to ask for

The instrument also unpicks a blockage. Where some of the protected trust information relates to a person under eighteen, the registrar may now disclose the parts that do not relate to that person, and may disclose information about the person under eighteen only where satisfied that the applicant has a legitimate interest. Previously the presence of a minor could hold up the whole disclosure, which protected nobody in particular and obscured everybody.

Two smaller changes sit alongside. Applications for protection of an individual's information no longer require supporting evidence in every case on certain grounds, and an applicant must now give a service address in place of a residential one, except where the entity has been removed from the register or the person is no longer a beneficial owner or managing officer. A parallel amendment removes a service address requirement for certain people with significant control in limited liability partnerships.

A fund or family structure that bought UK property through an overseas entity filed its trust information at registration, probably in 2022 or 2023, through an agent. Since then the trustee may have changed, a beneficiary may have been added, a protector may have retired and the entity may have been restructured. The obligation to file an update statement every year has been met, or it has been met by someone confirming that nothing changed without checking.

That was survivable while the information was difficult to reach. It is less comfortable now. A counterparty, a journalist or a claimant who can read an entity's registration number can begin an application, and what they may eventually be shown is the group's own filing. A group that does not know what its filing says has no view on whether the answer would be embarrassing, out of date or simply wrong.

For every overseas entity in the structure: the registration number, the date of the last update statement, who signed it, which trusts were disclosed and who was named in each capacity. That should be readable inside the group without asking the agent to send back a copy of the group's own filing, which is how most teams discover they never held one. Then give the annual update statement what a board meeting gets: a due date, a person, a check against the current trust deed and share register, and a record of what was confirmed. Where the filed position and the real position have drifted, the correction belongs on the register.

Each overseas entity is a governed record with its identifiers, ownership, officers and documents attached, and compliance obligations with due dates sit against that same record. Alethia does not file with Companies House. The annual update statement fits the shape directly: a recurring obligation with an owner, a due date and the filed document kept as evidence.

Ownership recorded alongside gives the group its own account of who holds what, which is what the filed position should agree with. Trust deeds and identity evidence can be scoped so they are visible only to the people who need them, and the audit trail shows when a filing was made and who confirmed it. Next July the update statement is already on somebody's list, with last year's attached to it.