The one-year anniversary of the UK Register of Overseas Entities has passed, signalling the commencement of the updating duty process. Entities are required to file an annual update statement, even if no changes have occurred in the overseas entity’s profile, beneficial owners or managing officers. To ensure compliance, every entity must understand the rules and file their annual update statements on time.
Here, we provide practical tips alongside the latest guidance for a smooth updating process.
Contacting Registered Beneficial Owners
Every entity should reach out to their Registered Beneficial Owners (RBO) or Managing Officers (MO) to confirm the accuracy of the filed information, officially known as a section 12 notice for an RBO. Non-compliance is considered a criminal offence, emphasising the importance of adhering to this obligation.
Meeting the Deadline
Entities must file their annual update statement within 14 days of their statement date, occurring within a year of registration or the last update statement. Even if your business structure is simple and unchanged, it’s important to check for additional owners, provide necessary info about current ones, and confirm no ownership changes during updates. Waiting until renewal might not leave enough time for these checks.
Verification by a UK Regulated Agent
Any changes in information must be verified by a UK-regulated agent, including details such as beneficial owners, addresses, and names. Considering the expected peak in demand for UK-regulated agents during the winter period, entities should allow ample time to engage these agents and follow internal processes for their appointment.
Filing for Trusts
Entities with trust information, whether previously reported to Companies House or highlighted in the update statement, must file their update statement online. This includes cases where no changes to trust information have occurred.
Preparation is Key
The key to a smooth update process lies in preparation. Entities should not wait until the last second to act; instead, they should familiarise themselves with the requirements and start the process sooner. Consider the following questions:
- Do we have more than one entity?
- Are there any changes?
- Are trusts involved?
- Do we need administrative support?
If the answer to any of these questions is ‘yes,’ starting the process earlier will contribute to a seamless update.
In conclusion, Overseas entities in the UK are encouraged to proactively engage in the updating process, ensuring timely compliance with the Register of Overseas Entities regulations.
