Trust beneficial ownership register
Since 1 April 2023 the trustees of every trust must record who ultimately owns or controls it and lodge that register with the Master of the High Court, electronically, and keep it current. Most trusts registered before then have never done it, and the bank is usually the first to ask. We build the register for your existing trust from the deed and lodge it on the Master’s online system. Fixed price, in writing.
Independent paperwork service. ProperSA is an independent private company, not the Master of the High Court. The trustees can complete the Master’s template and upload it themselves at no charge. Our fee pays for reading the deed properly, identifying every beneficial owner the Act names, completing the template correctly and lodging it. This page is for a trust that already exists. A new trust gets the register filed as part of trust registration.
What is included
- Every beneficial owner identified from the deed and the letters of authority: the founder, each trustee, each named beneficiary, and anyone who controls the trust from outside it
- Company or trust shareholders and beneficiaries traced through to the natural persons behind them
- The Master’s register template completed with the details it asks for, checked against the identity documents
- The register lodged on the Master’s Trust Beneficial Ownership Register online system, and the confirmation saved in your portal
- A trustee file note on the records section 11A obliges the trustees to keep, including the certified identity copies
- A change protocol sheet: what to send us when a trustee, beneficiary or controller changes, and what it costs
Why it matters now
The duty comes from section 11A of the Trust Property Control Act 57 of 1988, inserted by the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 22 of 2022. A trustee who fails to record the information or fails to lodge the register commits an offence, and the amended Act provides for a fine of up to R10 million, imprisonment of up to five years, or both.
The register is not public. It is available to SARS, the Financial Intelligence Centre and the prosecuting authorities. The practical pressure comes from somewhere else: banks, attorneys, estate agents and other accountable institutions must establish who the beneficial owners of a trust are before they deal with it, and they ask for the Master’s register as proof. A trust that cannot produce it stalls at the bank.
Who is on the register. The Act names the founder, every trustee, every beneficiary referred to by name in the deed, and any natural person who directly or indirectly owns the trust property or exercises effective control over the trust. Every entry must be a natural person identified by name, so where a company or another trust is a trustee or beneficiary, the register looks through it to the people behind it.
How ordering works
- Order online and send us the trust deed, the letters of authority and the details of everyone named in them.
- We identify every beneficial owner, complete the Master’s template and send it to the trustees to confirm within 2 business days.
- We lodge it on the Master’s online system and place the confirmation and your trustee file note in the portal.
Not sure this is the right one for you? Ask us first and you get a written answer within one business day.
What we will need from you
The Master lodges nothing on paper and accepts only its own template, so the work is getting every person and every detail right before it is uploaded.
- The trust deed and any amendments, so the founder, the trustees, the named beneficiaries and any power to control the trust can be read from the source.
- The letters of authority issued by the Master, which carry the trust number and the Master’s office the trust is registered at.
- For the founder, every trustee and every named beneficiary, the details the Master’s template asks for: full names, identity or passport number, date of birth, nationality, residential address and contact details, and their role in the trust.
- Certified identity or passport copies of each of them. The trustees are required to keep these on file, and we check the register against them.
- Where a trustee or beneficiary is a company or another trust, the documents that trace through to the natural persons: share registers, that trust’s deed, letters of authority.
- A resolution or mandate from the trustees authorising us to lodge on their behalf, which we send you to sign.
- An email address and cellphone number for one trustee, for the Master’s online system.
Frequently asked questions
Who counts as a beneficial owner of a trust?
Section 11A of the Trust Property Control Act lists them: the founder, every trustee, every beneficiary referred to by name in the trust deed, and any natural person who ultimately owns the trust property or exercises effective control over the trust. Every one of them must be a named natural person. Where a trustee or beneficiary is a company or another trust, the register looks through it to the people behind it.
Our trust was registered years ago. Does this apply to us?
Yes. The duty applies to every trust registered with the Master, however old, since 1 April 2023. The Master exempts only trusts that have been formally terminated and dormant trusts. If your trust holds property, a bank account or shares, it is not dormant.
What happens if the register is not lodged?
A trustee who fails to record the beneficial ownership information or fails to lodge the register commits an offence, and the amended Act provides for a fine of up to R10 million, imprisonment of up to five years, or both. Banks and other accountable institutions also ask for the register under the Financial Intelligence Centre Act before they will deal with the trust.
How is it lodged?
Electronically only, on the Master’s Trust Beneficial Ownership Register online system, using the Master’s own spreadsheet template. The Master states that no hard copy lodgement is accepted. We complete the template from your deed and letters of authority and upload it, then keep the confirmation in your portal.
What if a trustee or beneficiary changes later?
The register must be kept accurate and updated within a reasonable time of the change. Send us the new details and we refile for the same fixed fee, only when a change actually happens. The trustees must also keep certified identity copies of every beneficial owner on file.
Keep exploring
- Trust registration, R1 490, which includes this register for a new trust
- Company beneficial ownership filing at CIPC, R490
- How to register a trust in South Africa
- Deceased estate reporting pack
This is an administrative service performed with the trustees’ authority. ProperSA does not draft or amend trust deeds and does not give legal or tax advice on the trust; where a matter needs an attorney or a registered tax practitioner, we say so and refer you before any work starts. The legal position is as stated in the Trust Property Control Act as amended and the Master’s published guidance at the date of writing; confirm anything you rely on with the Master or your attorney.