Part 1: Registration of Overseas Entities Updating Section 7: Updating duty
This section explains that registered overseas entities are required to annually update the statements and information provided to the Registrar and must do so within 14 days after the end of the ‘update period’. The first update is 12 months beginning with the date of the overseas entity’s registration.
	The information required at update is set out in subsection (1); the required information includes a ‘record of events’ within the update period as regards to changes of beneficial ownership within the period. The entity remains obliged to take reasonable steps to identify beneficial owners, even if none could be identified at the time of registration or the previous update (as the case may be). Subsections (2) to (10) provide further details and explanation about updating requirements, the "update period" and explain that the entity can provide updates earlier than required if they choose to do so.
	Where an entity chooses to update before the end of the update period, this has the effect of re-setting the clock in respect of when the next update is due.
	Example: Update period
An example would be where an overseas entity registers on 1 January 2023. Its update period would therefore expire on 31 December 2023, with the update due in respect of that period by 14 January 2024. If the overseas entity chooses instead to update on 6 July 2023 and notifies the Registrar that it has shortened its update period so that the update is in respect of the period between 1 January and 6 July, the next update period will run from 7 July 2023 to 6 July 2024, with the update due 14 days after the expiry of that update period.
	Subsections (3) and (4) require an overseas entity, when complying with its updating duty, to provide additional information and statements about trusts, where a registrable beneficial owner of the overseas entity is or was a trustee.
	Subsections (11) and (12) provide that the Secretary of State may amend the update period by regulations. This would allow the Government, were it to become clear that the 12-month update period was not sufficient, to shorten or extend it as the case may be. Any such regulations would be subject to affirmative resolution procedure.