The UK’s Register of Overseas Entities (ROE) is a relatively recent development aimed at increasing transparency and combating illicit activities in property ownership. Introduced under the Economic Crime (Transparency and Enforcement) Act 2022, the ROE requires overseas entities owning or intending to own property in the UK to disclose their beneficial ownership details. This blog provides a detailed overview of the Register of Overseas Entities, including who needs to register, how to comply, and the consequences of non-compliance.
What is the Register of Overseas Entities (ROE)?
The Register of Overseas Entities (ROE) is a publicly accessible register maintained by Companies House. It records information about overseas entities and their beneficial owners to ensure greater transparency in property ownership across the UK. This initiative aims to reduce opportunities for money laundering and other financial crimes by revealing who ultimately controls property assets.
Who Needs to Register?
Overseas entities that:
- Own property or land in the UK;
- Intend to acquire property or land in the UK;
- Disposed of property or land in England or Wales on or after 28 February 2022, in Scotland on or after 8 December 2014, or in Northern Ireland on or after 5 September 2022.
An “overseas entity” refers to a company, partnership, or other legal structure governed by laws outside the UK.
Information Required for Registration
To register with the ROE, the following information must be provided:
- Entity Details: Name, legal form, governing law, registered office, and country of incorporation.
- Beneficial Ownership Details: Full name, date of birth, nationality, and residential address of beneficial owners, as well as details of their control over the entity.
- Managing Officers: Information on directors, partners, or other managing officers if there are no beneficial owners.
- UK Regulated Agent: A UK-based agent who is supervised for Anti-Money Laundering (AML) purposes must verify the information before submission.
How to Register
- Appoint a UK-Regulated Agent: Overseas entities must engage a UK-regulated agent, such as The Tax Lead Limited to conduct identity verification checks.
- Complete the Application Form: Submit the relevant information to Companies House, either online or via a paper form.
- Pay the Registration Fee: A registration fee applies.
- Receive a Unique ID: Once registered, the entity will receive a unique Overseas Entity ID.
Compliance Deadlines
Overseas entities that already own UK property were required to register with the ROE by 31 January 2023. For entities acquiring property, registration must be completed before the transaction can proceed.
Annual Updates
Entities listed on the Register of Overseas Entities (ROE) must submit an annual update to Companies House to confirm the accuracy of the information or report any changes. Failure to do so could result in penalties.
Consequences of Non-Compliance
Non-compliance with the ROE requirements can have serious consequences, including:
- Restrictions on registering ownership of property with HM Land Registry.
- Criminal penalties, including fines of up to £2,500 per day and potential imprisonment for directors or officers.
- Difficulty selling, leasing, or mortgaging property in the UK.
How Can We Help?
As a UK-regulated agent authorised to handle ROE registrations, The Tax Lead Accountants can guide you through every step of the process, from verifying beneficial ownership details to submitting the necessary filings with Companies House. Our team ensures compliance while minimising administrative burdens, giving you peace of mind.
Final Thoughts
The Register of Overseas Entities is a significant step towards enhancing transparency in property ownership within the UK. While compliance may seem complex, understanding the requirements and working with experienced professionals can simplify the process. If you’re an overseas entity navigating the ROE requirements, don’t hesitate to reach out for expert assistance.
The Tax Lead Accountants | Phone: 020 3376 0933 | Email: info@thetaxlead.co.uk