Is your charity an unincorporated association or trust? Do you have an interest in Scottish property?

If so, have you considered whether you need to provide information to the Register of Persons Holding a Controlled Interest in Land?

The Register of Persons Holding a Controlled Interest in Land (RCI) came into force on 1 April 2022. At present, certain landowners and tenants must supply the RCI with information regarding the ownership and control of land by 31 March 2023. Failure to do so is a criminal offence and could potentially result in a £5,000 fine.

Scottish Ministers have recently proposed to extend the RCI deadline by one year. If the Scottish Parliament approves the proposal, it will be 1 April 2024 before the offence provisions will be enforced. Confirmation of the extension is awaited.


The RCI is a new register of those people or entities who have a “controlling interest” in respect of or “significantly influence” the use, development and management of Scottish property. It is a public register and free to search.


The RCI was introduced to improve transparency of land ownership in Scotland. It is not a register of owners of land. However, it aims to make it easier for the public to determine who has control over areas of land and buildings where that information is not otherwise publicly available.


Owners of land or a tenant under a long lease must provide details of any party with significant control or influence in relation to that land or property.

SCIOs and charitable limited companies are exempt from having to register with the RCI. However, a trust, partnership or unincorporated association with a “qualifying interest” in Scottish property must register with the RCI.

This is likely to include a member of an unincorporated association or a trustee of a trust who is not the registered owner of the property (or the tenant under a lease of 20 years or more) but can direct the activities of the property on behalf of their organisation. It may also include committee members who are involved in making the decisions about the property in question. Much will depend on the individual facts and circumstances.


Registration is done via the Registers of Scotland website. Further details and guidance can be found here.

Registers of Scotland are encouraging 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.

In the meantime, if you need any guidance on the application of the RCI, or assistance in completing the registration please contact MacRoberts' Commercial Property or Charities & Third Sector teams.