Beneficial ownership registers in the Overseas Territories and Crown Dependencies

This briefing sets out progress on implementing public registers of beneficial ownership in the UK’s Overseas Territories and Crown Dependencies.

For information on the UK and UK law, see the Library briefing Registers of beneficial ownership.

What is beneficial ownership?

Beneficial ownership refers to the person who ultimately owns or controls an asset (for example, a property or a company).

The concept of beneficial ownership exists because the direct legal owner of an asset is not necessarily the person who actually controls and benefits from it. For example, the registered legal owner of a residential property may be a company registered overseas, which is controlled by an individual.

There are both lawful and unlawful reasons for wanting to separate the legal and beneficial owners of something. Nonetheless, registers of beneficial ownership can provide transparency and play an important role in the fight against corruption, tax evasion and money laundering.

Registers of beneficial ownership

Registers of beneficial ownership are records of who the beneficial owners of something are. When a regulator or an official registrar collects and collates this information in one place, it creates a central register of beneficial ownership. Registers of beneficial ownership might be:

• publicly available (‘public access registers’), or
• only available to law enforcement, tax authorities and those with a legitimate interest, such as journalists (‘legitimate access registers’)

The UK introduced its own publicly accessible register in 2016.

What is the UK’s relationship with the Overseas Territories and Crown Dependencies?

The Crown Dependencies (or ‘CDs’; Guernsey, Jersey and the Isle of Man) and the 14 UK Overseas Territories (or ‘OTs’, which include Bermuda, Gibraltar and the Turks and Caicos Islands) are not part of the UK and have their own governments and legislatures.

There is a constitutional convention that the UK Parliament does not legislate for the CDs without the consent of their governments.

There is no constitutional convention to stop the UK Parliament from legislating for the OTs without the consent of their governments, though such legislation remains rare. One example was in 2018, when the UK Parliament passed the Sanctions and Anti-Money Laundering Act, which required the UK Government to introduce a draft order in council requiring the OTs to introduce publicly accessible registers of beneficial ownership. The legislation prompted extensive criticism from OT governments.

What does the UK Government expect?

The UK Government had expected public access registers to be in place in all OTs and CDs by 2023. However, this deadline was not met.

The government continues to say that it expects all OTs and CDs to introduce publicly accessible registers, but that it will allow legitimate access registers as an “interim step”. While the order in council was drafted, in 2020 the government said that because there were “firm commitments” from the OTs to introduce public registers, the order would not be used. It said it would keep this decision under review.

Governments can also share ownership information via a series of exchange of notes agreements between the UK, CDs and OTs, in place since 2016.

What progress has been made?

Public access and legitimate access registers are already introduced, or due to be introduced, in several OTs and CDs.

Public access registers are:

• already introduced in three OTs: Gibraltar (since 2020), Monserrat (since 2024) and St Helena, Ascension and Tristan da Cunha (since 2025)
• expected to be introduced in one OT in 2026: the Falkland Islands

Legitimate access registers are:

• Already introduced in two OTs: the Cayman Islands (since 2025) and the Turks and Caicos Islands (since 2025).
• Expected to be in introduced in three more OTs in 2026: Anguilla, Bermuda and the British Virgin Islands.
• Being consulted on in two CDs: Jersey and Guernsey. All three CDs have committed to expanding beneficial ownership access to those with a legitimate interest. All three CDs currently have obliged entity-access registers (registers open to people in anti-corruption or anti-money laundering roles, or business conducting customer due diligence).

Some OT and CD governments have said they have not yet implemented public registers due to privacy concerns, citing a European Court of Justice case in 2022 and the risk of similar potential judgments in local courts. The UK Government notes that the European case does not directly apply to either the CDs or OTs (PDF).