Register of Overseas Entities (ROE): New Requirements – July 2025

Changes introduced under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) mean overseas entities may be required to provide additional information in their next Register of Overseas Entities (ROE) update statement from a later date which has yet to be confirmed.

What’s changing with the Register of Overseas Entities?

Entities will now be required to disclose details regarding the “pre-registration period” (28 February 2022 up to either an entity’s registration date or 31 January 2023, depending on when registration occurred).
Specifically, if the entity owned UK property or land within this timeframe, information must be provided about:

• Registrable beneficial owners
• Trusts associated with the entity
• Beneficiaries of any relevant trusts

provided this information has not already been disclosed to Companies House at the time of registration. Please note: an update on managing officers during this period is not required.

Timings

For entities whose update statements are due between 31 July 2025 and 31 October 2025, the required information can either be included in the 2025 update or, if more time is needed, deferred until the next annual update. Update statements from 1 November 2025 must include this information.

ROE Verification Requirement

All information relating to the pre-registration period must be independently verified by a UK-regulated verification agent within three months of the update statement.

How JTC Can Assist You

At JTC, our role is to help clients adhere to the increasingly complex rules and regulations. As a UK-regulated verification agent, JTC (UK) Limited can manage the verification process of your pre-registration information and guide you through the new requirements. Contact Matthew Allen or Amber Aliu to find out more. You can also find additional information by visiting our Corporate Services page.