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Chamber and committees

Question reference: S6W-17648

  • Asked by: Fulton MacGregor, MSP for Coatbridge and Chryston, Scottish National Party
  • Date lodged: 3 May 2023
  • Current status: Answered by Mairi Gougeon on 15 May 2023


To ask the Scottish Government, regarding the recently-introduced Land Reform (Scotland) Act 2016 (Register of Persons Holding a Controlled Interest in Land) Regulations 2021, what mitigations it can offer to the Church of Scotland, given that the church's over 6,000 congregations are all registered as separate charities and have reportedly described attempting to comply with the new regulations as extremely logistically difficult, expensive, and complicated to roll out.


The Register is a significant transparency measure that will shed light on who makes decisions about Scotland’s land. It has been live since 1 April 2022 and there is no charge to make a submission to the Register. For some, there may be a resource cost for the time taken to gather the information they require as part of their preparation prior to making a submission. The greater the number of properties owned, the greater the effort required is likely to be.

The Church of Scotland are one of the largest owners by volume of property titles held. This makes it important for the integrity of the Register that they comply with the RCI.

On 16 March 2023 the Scottish Parliament unanimously supported a 12-month extension to the transitional period to 1 April 2024 before offence provisions take effect. This is easing the burden by allowing those in scope to spread it over the coming year.

In letters of 16 February 2023 and 27 March 2023, the Scottish Government offered the Church of Scotland the option of another meeting with Registers of Scotland and Scottish Government officials to discuss how they can work together to help achieve compliance. The Scottish Government has not yet received a response to that offer, however officials will be in touch with the Church of Scotland to follow up on this.

The Scottish Government and Registers of Scotland are working together to deliver an additional engagement plan to help support stakeholders through the registration process. This will include additional awareness raising and a review of the existing guidance. It will not include further legislative intervention or legal advice.