The Trust Registration Service is HMRC’s online register of the people behind trusts, kept under the Money Laundering Regulations 2017. Any trust liable to a UK tax must register, and so must most UK express trusts with no tax to pay unless they fall within the exclusions in Schedule 3A. New registrations are generally due within 90 days, changes must be recorded within 90 days, and a trust with a tax liability must also confirm every year by 31 January that its details are up to date.

What is the register and who is responsible for it?

Regulation 45 of the Money Laundering Regulations 2017 requires HMRC to maintain a register of the beneficial owners and potential beneficiaries of taxable relevant trusts, and places the duty to supply the information on the trustees. The register was later widened to many trusts with no tax liability. HMRC’s guidance says the information is collected to make sure trusts comply with anti money laundering rules, and it may be shared with law enforcement and with third parties whose requests meet the requirements of the regulations.

All trustees are equally legally responsible, but they must nominate a lead trustee as HMRC’s main contact. The lead trustee, or an agent acting for them, must register the trust and keep the registration up to date.

Which trusts must register?

HMRC’s guidance, updated on 30 June 2026, says a UK resident trust must register if it is liable to Income Tax, Capital Gains Tax, Inheritance Tax, Stamp Duty Land Tax, Land and Buildings Transaction Tax or Land Transaction Tax on UK assets or income. A non UK resident trust must register if it becomes liable to any of those taxes on UK assets or income. Registration is still needed where a relief covers the liability but has to be claimed on a Self Assessment return.

The following must register even with no tax to pay:

  • all UK resident express trusts, unless excluded under Schedule 3A;
  • trusts that need a Unique Taxpayer Reference, for example to report non resident Capital Gains Tax;
  • non UK resident express trusts that acquire UK property after 6 October 2020, that acquired UK property before that date and still held it on 30 June 2026, or that have at least one UK resident trustee and enter a business relationship in the UK.

Which trusts are excluded?

Trusts listed in Schedule 3A, called excluded express trusts, need not register unless they are liable to UK tax. The current guidance includes a general exclusion for a trust that holds no interest in UK real property, holds no assets of appreciable worth above £2,000, has never held property with a cumulative value above £10,000, has income of no more than £5,000 a year and has no UK tax liability. Only one trust per settlor can use this general exclusion.

Specific exclusions include, among others:

  • statutory trusts created by court order or by law;
  • trusts holding the money or assets of a UK registered pension scheme;
  • trusts holding life insurance policies that pay out only on death, illness or disability, discussed in life insurance written in trust;
  • trusts for registered charities;
  • trusts set up to open a bank account for a child;
  • will trusts that receive assets from the estate and are closed within two years of death;
  • pilot trusts holding less than £100 and set up before 6 October 2020;
  • co ownership trusts holding property jointly owned as tenants in common, and trusts created by a deed of variation as part of administering an estate.

HMRC recommends taking professional advice where it is unclear whether an arrangement is a trust at all or whether it must register.

What are the registration deadlines?

Type of trust Deadline
Non taxable, created after 6 October 2020 Within 90 days of creation or of becoming liable for tax, or by 1 September 2022 if later
Non taxable, created before 6 October 2020 By 1 September 2022
Taxable, created on or after 6 April 2021 Within 90 days of becoming liable for tax, or by 1 September 2022 if later
Taxable, created before 6 April 2021, first liable to Income Tax or Capital Gains Tax By 5 October after the tax year of first liability
Taxable, created before 6 April 2021, previously liable to Income Tax or Capital Gains Tax By 31 January after the tax year of liability
Taxable, created before 6 April 2021, liable to another tax such as Inheritance Tax By 31 January after the tax year of liability
Non UK trust holding UK property acquired before 6 October 2020 By 1 September 2027; HMRC says the service cannot yet accept these

HMRC’s example: a trust created before 6 April 2021 that first received taxable interest in May 2024 should have registered by 5 October 2025.

What information has to be given?

Every registration needs the trust’s name and creation date, whether it is an express trust, and details of the lead trustee, other trustees, settlors, protectors and beneficiaries. Beneficiaries not yet identifiable, such as future grandchildren, can be recorded as a class. Details must match official documents. Taxable trusts must also give the type of trust, how it was set up and its assets with approximate values, whether shares, business interests, property or money.

The lead trustee needs an Organisation Government Gateway user ID, a different one for each trust; an individual user ID will not work. Agents register through their agent services account. Progress can be saved for 28 days. Any questions skipped must be answered within 90 days of registering. A taxable trust receives a Unique Taxpayer Reference, usually within 15 working days, which it needs to file the trust and estate tax return; a non taxable trust receives a Unique Reference Number.

What does the duty to update involve?

HMRC’s guidance on managing a registration sets out the ongoing obligations:

  • Non taxable trusts must report all changes within 90 days of them occurring. No annual declaration is needed.
  • Taxable trusts must declare every year by 31 January that the details are accurate and up to date, whether or not anything has changed, and must report changes to a beneficial owner’s name, date of birth, country of residence or nationality within 90 days.
  • Trustees liable to Income Tax or Capital Gains Tax also confirm at Question 20 of the SA900 that they have updated the register or confirmed there are no changes.
  • A trust that registered as non taxable and later becomes taxable must tell HMRC through the service and will be issued a Unique Taxpayer Reference in place of its reference number.
  • When a trust ends, the trustees close it on the service and give the end date. HMRC asks them not to write in.

What penalties apply?

HMRC can charge a fixed penalty of £5,000 for failing to register or to keep the information up to date. Its published approach is to send a letter setting a time limit to put things right and to charge only if the trustees do not act within it; penalties are decided case by case, carry no interest and can be reviewed or appealed.

The practical sanction is often commercial. Banks, solicitors and accountants carrying out customer due diligence on trusts may ask for a proof of registration document, and HMRC’s guidance explains how to download it. Agents also need separate authority to see a client trust’s record, explained in authorising agents for trusts and estates.

What mistakes come up most often?

  • Assuming a trust with no tax to pay never needs to register. Most UK express trusts must, unless Schedule 3A excludes them.
  • Missing the 90 day window after a trust first becomes liable to tax, for example when an asset is first sold at a gain.
  • Forgetting the 31 January declaration in years when nothing has changed.
  • Recording a class of beneficiaries when the individuals can reasonably be identified; HMRC’s guidance says they should then be named.
  • Leaving a will trust on the register, or off it, without checking whether it was closed within two years of death.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.