Updating Your Statement for the UK Register of Overseas Entities

Updating Your Statement for the UK Register of Overseas Entities
The one-year milestone of the UK Register of Overseas Entities has passed, marking the commencement of the updating duty process. Every entity, regardless of changes, is required to submit an update statement, and it is crucial for each entity to familiarise itself with the regulations and establish suitable timeframes. Some entities are discovering that they have less time than anticipated.

Consider the following practical tips in conjunction with the latest guidance:

Contact Registered Beneficial Owners:
Every entity should get in touch with their Registered Beneficial Owners (RBO) or Managing Officers (MO) to confirm the accuracy of the filed information. This is officially called a section 12 notice for an RBO.

Respondents have a month to respond, and overseas entities should factor this into their timeframes. Non-compliance with this obligation constitutes a criminal offence, even if the overseas entity believes it already possesses the RBO information.

Don’t miss the Deadline:
The statement date falls within a year of the overseas entity’s registration or the last update statement. Overseas entities must file the update statement within 14 days.
Even for entities with no changes, due diligence is necessary to declare that there are no additional beneficial owners, the required information about each registrable beneficial owner is available, and there is no reason to believe any changes occurred during the update period.

Entities waiting until their renewal date may find the 14-day window insufficient, for example, a change of address for a managing officer can be easily missed. Allowing enough time to complete a section 12 notice will help, emphasising the importance of planning and checklists.

Verification by a UK Regulated Agent:
Changes in information, including beneficial owners, addresses, and names, must be verified by a UK regulated agent.

As a considerable number of filings occur in January and February, it’s advisable to engage a UK regulated agent promptly and follow internal processes for their appointment.

Trusts Filing Requirement:
Entities with trust information, whether previously reported or newly highlighted, must file their update statement, even in the absence of changes.

All trusts need to comply with the update process.

Next Steps
The key to a seamless update process is preparation. Overseas entities should not rely on their renewal date alone but should familiarise themselves with the requirements and start early if changes, trusts, or administrative support are involved.

Overseas entities should ask themselves the following questions:

• Do we have more than one entity?
• Are there any changes?
• Are there trusts involved?
• Do we need administrative support?

If any of the answers are ‘yes,’ it’s advisable to start the process sooner. Engaging a UK regulated agent can assist with all aspects of the update process.

Lastly, as this is an evolving legal area, overseas entities must stay informed about the latest guidance from Companies House to meet the current requirements. While future reforms are legislated in the Economic Crime and Corporate Transparency Act 2023, which are not yet in force, overseas entities must prepare to take appropriate action when these provisions come into effect.

Any filings on the ROE must be verified by an assured agent of Companies House. Sovereign Corporate & Trustee Services Limited is an a Companies House assured agent that can verify filings on the ROE. We can get this done for you in a timely manner, to the required standard and for a competitive rate.

To ensure compliance, do not delay. Get in touch with Stuart Stobie today to find out how we can help below or call 0044 (0)1244 901350.