Register of Overseas Entities (ROE) — the UK guide
Who must register, the role of the ACSP, the five-step process, annual renewal, and the consequences when an overseas entity holding UK land doesn't comply.
By Mehmood Rajoka · Last updated 2026-06-08
TL;DR — Quick Summary
- •The Register of Overseas Entities (ROE) is a Companies House register, introduced by the Economic Crime (Transparency and Enforcement) Act 2022, requiring overseas entities that own UK land to disclose their beneficial owners.
- •Almost every overseas entity that owns qualifying UK real estate must register, with beneficial ownership information verified by a UK-supervised agent.
- •Failure to register prevents the overseas entity from disposing of UK land — Land Registry will not register a transfer, lease, or charge from an unregistered entity.
- •Registration must be renewed annually. The verification statement from the UK-supervised agent must be no more than 3 months old at the date of filing.
- •The 2023 Economic Crime and Corporate Transparency Act and subsequent amendments tightened ROE — including powers for Companies House to challenge filings, expanded definitions of 'overseas entity', and clarification of trust-related beneficial ownership.
Answer-first summary
What is the Register of Overseas Entities?
The Register of Overseas Entities (ROE) is a Companies House register introduced by the Economic Crime (Transparency and Enforcement) Act 2022. It requires overseas (non-UK) entities that own UK land to disclose their beneficial owners, with information verified by a UK-supervised Authorised Corporate Service Provider (ACSP). The purpose is to bring overseas-entity ownership of UK property into transparency — closing what had been a major route for illicit finance through opaque offshore structures. Failure to register prevents Land Registry from registering dealings — effectively freezing UK land transactions.
- Companies House register since 2022
- Beneficial-owner verification via UK ACSP required
- Annual renewal mandatory
- Non-registration blocks Land Registry dealings
Who must register
Four scope categories, including retrospective coverage of pre-2022 ownership:
Overseas entities owning UK freehold land
Any non-UK legal entity owning freehold land in England, Wales, Scotland, or Northern Ireland that meets the relevant acquisition date threshold.
Overseas entities holding qualifying leases
Non-UK entities holding leases granted for more than 7 years, where the lease is in scope of the regime. The threshold and specific in-scope leases vary by jurisdiction within the UK.
Retrospective coverage
ROE applies retrospectively to certain pre-existing ownership, with specific transition rules for entities that already owned UK land when the 2022 Act came into force. Most affected entities had to register by January 2023.
Future acquisitions
Any overseas entity acquiring qualifying UK land after the regime came into force must register before completing the acquisition. Land Registry will not register a transfer to an unregistered overseas entity.
The 5-step registration process
Overseas entities cannot file directly — every step depends on a UK-supervised ACSP:
1. Engage a UK-supervised agent (ACSP)
An Authorised Corporate Service Provider — typically a UK-supervised law firm, accountancy practice, or specialist corporate services provider — must conduct the beneficial-owner verification and submit the verification statement. The entity cannot file directly.
2. Identify beneficial owners and managing officers
Beneficial owners are the natural persons who ultimately own or control the overseas entity (>25% ownership, control, significant influence, etc.) Where no beneficial owner can be identified, managing officers (directors, equivalent senior figures) must be disclosed instead.
3. Verify identity via the ACSP
The ACSP collects ID, address, ownership documentation, and verifies the beneficial-owner identifications against reliable independent sources. The verification statement is the formal output.
4. File at Companies House
The ACSP files the registration application at Companies House with the verification statement. Companies House issues an Overseas Entity ID. The verification statement must be no more than 3 months old at filing.
5. Annual renewal
Registration must be renewed annually. The renewal updates any changes in beneficial ownership and re-verifies the identifications. Missing the renewal deadline carries criminal-offence exposure for officers.
Consequences of non-registration
- Land Registry will not register transfers, leases, or charges from the unregistered entity — effectively freezing UK land dealings
- Criminal offences for the overseas entity, its officers, and (in some cases) the ACSP that failed to file or verify properly
- Civil penalties — financial penalties scale with the value of land involved
- Publication of non-compliance — Companies House lists overseas entities in default, creating reputational exposure for any related UK-supervised intermediaries
- Inability to grant valid charges — lenders cannot rely on charges over UK land from unregistered overseas entities, blocking refinancing
The UK agent (ACSP) — what they must do
If you're a UK firm acting as an ACSP, four primary obligations:
Authorised Corporate Service Provider (ACSP) status
The agent must be a UK-supervised entity registered as an ACSP at Companies House. The 2023 Economic Crime and Corporate Transparency Act introduced ID verification requirements for ACSPs themselves — adding integrity to the chain.
Reliable independent verification
The ACSP must verify beneficial-owner identities using documents, data, or information from reliable, independent sources — same standard as MLR 2017 Reg 28 CDD verification.
Verification statement validity period
The verification statement must be no more than 3 months old at the date of filing. Stale verification rejects the application.
Ongoing liability
The ACSP remains a verification party for the overseas entity's compliance. Knowingly filing false information is a criminal offence with serious consequences — and reputational damage for the broader practice.
FAQ
Answer-first summary
What is the Register of Overseas Entities (ROE)?
The Register of Overseas Entities is a Companies House register introduced by the Economic Crime (Transparency and Enforcement) Act 2022. It requires overseas entities that own UK land to disclose their beneficial owners, with the information verified by a UK-supervised agent (an Authorised Corporate Service Provider). The purpose is to bring overseas-entity ownership of UK property into transparency — closing what had been a major route for illicit finance through opaque offshore structures.
Answer-first summary
Who must register on the ROE?
Any overseas (non-UK) legal entity that owns qualifying UK land — freehold land in England, Wales, Scotland, or Northern Ireland, or leasehold interests granted for more than 7 years where the lease is in scope of the regime. The regime applies retrospectively to certain pre-existing ownership (most affected entities had to register by January 2023) and prospectively to any new acquisition. Land Registry will not register transfers to unregistered overseas entities.
Answer-first summary
How do I register on the ROE?
Five steps. (1) Engage a UK-supervised agent registered as an Authorised Corporate Service Provider (ACSP) — typically a UK law firm or accountancy practice. (2) Identify beneficial owners and managing officers of the overseas entity. (3) The ACSP verifies the beneficial-owner identities using reliable independent sources. (4) The ACSP files the registration application at Companies House with the verification statement (which must be no more than 3 months old). (5) Renew annually, with updates for any changes in beneficial ownership.
Answer-first summary
What happens if an overseas entity doesn't register?
Five consequences. Land Registry will not register transfers, leases, or charges from the unregistered entity — effectively freezing UK land dealings. Criminal offences for the overseas entity, its officers, and in some cases the ACSP. Civil penalties scaling with the value of land involved. Publication of non-compliance, creating reputational exposure. Inability to grant valid charges over UK land — blocking refinancing and lender security.
Answer-first summary
What is an Authorised Corporate Service Provider (ACSP)?
An Authorised Corporate Service Provider is a UK-supervised entity registered at Companies House and authorised to act as a verification party under the ROE regime. ACSPs are typically UK-supervised law firms, accountancy practices, or specialist corporate-services providers. The 2023 Economic Crime and Corporate Transparency Act introduced ID verification requirements for ACSPs themselves, adding integrity to the verification chain. Overseas entities cannot file ROE registrations directly — they must work through an ACSP.
Answer-first summary
How often must ROE registration be renewed?
Annually. The renewal updates any changes in beneficial ownership, re-verifies the identifications via the ACSP, and refreshes the verification statement (which must be no more than 3 months old at filing). Missing the renewal deadline carries criminal-offence exposure for the entity's officers and triggers Land Registry restrictions on dealings. Most ACSPs operate annual reminders for their ROE-registered overseas entity clients.