In the January 2025 report, you only need to submit data for any owner that has been added to your account after 01.01.2024.
Anybody you have signed up before this date does not need to be included in the January 2025 report.
In the following years, you will need to report on all owners, but this first year allows you to collect data on fewer owners as it’s only asking for owners added from January 2024. So you can complete due diligence data just for these owners, reducing admin time.
