Proposed changes to RCI submission period
Scottish Government Ministers propose to extend the time period for compliance for RCI submissions by a period of 12 months.
An affirmative SSI has been laid at the Parliament for its approval.
Should the instrument be approved, offence provisions would take effect from 1 April 2024.
Find out more information from the Scottish Government.
Timing of the Parliament’s consideration and further information on the SSI will become available on the Committee pages of the Scottish Parliament website
Find out more information from the Net Zero, Energy and Transport Committee.
Ministers listened to concerns raised by some stakeholders, and recognised the wider challenges caused by issues such as Brexit, the pandemic, and the current economic pressures.
It was concluded that the proposal to extend the transitional period by 12 months will ease the burden and give those in scope of the RCI more time to prepare.
RCI continues to be open to submissions.
Should the instrument be approved by Parliament this does not change the duty to register. All those in scope of the RCI are still expected to comply.
The proposed 12-month extension, if approved, will mean you have until 1 April 2024 to make your submission.
The RCI opened on 1 April 2022 and those in scope have an existing duty to register.
Ministers encourage everyone who is eligible to engage with the process as early as possible and give themselves plenty of time to register before the proposed new 1 April 2024 deadline.
The proposed extension of the period in which to submit does not impact on your duty to register or any submissions that have already been made to the RCI.
When the Register of Persons Holding a Controlled Interest in Land (RCI) and the Register of Overseas Entities (ROE) were initially in policy development the view of both the Scottish Government and the UK Government was that double reporting should be avoided where possible.
Our current understanding is that this has not changed and that the Scottish Government will consider the extent of duplication with the ROE and then decide whether it is appropriate to amend the RCI regulations.
It’s important to note that in the meantime overseas entities that are in scope of RCI must register irrespective of ROE and make arrangements to comply with RCI legislation ahead of the transition period ending and criminal offences coming into force.
Should the Parliament approve the deadline extension the Scottish Government and Registers of Scotland will work together to continue to raise awareness and help support stakeholders through the process.