As part of the UK government’s ongoing efforts to improve transparency and align with international anti-money laundering regulations, further updates to the Trust Registration Service (TRS)are expected to take effect in early 2026. These changes will arise from the upcoming “Money Laundering and Terrorist Financing (Amendment and Miscellaneous Provision) Regulations”, published in draft form in Summer 2025.
The forthcoming Regulations are expected to expand the scope of trusts required to register on the TRS whilst introducing some exclusions for low-risk, low-value trusts. This is the ideal time to review your Trusts position to ensure compliance with the TRS before the Regulations are introduced.
WHAT is the Trust Registration Service
The Trust Registration Service is a database managed by HMRC that gathers information on each trust, such as details on the settlor, trustees, beneficiaries and potentially the assets held. This is in response to improve and meet anti-money laundering obligations.
WHEN must a Trust Register
For trusts created on or before 3 June 2022, the registration deadline was 1 September 2022. Trusts created after 3 June 2022 must register within 90 days of creation or becoming liable for UK tax.
The TRS information must be updated annually or within 90days if there are any amendments required. HMRC’s guidance states that a trustee can face a penalty of £5,000 per trust for any failure to register on time or keep the register up to date.
WHO must Register
- All UK express trusts, whether or not they have tax liabilities, are now required to register with the TRS unless explicitly exempt.
- Non-UK trusts are also within scope if they acquire UK land or have at least one UK-based trustee and enter into a business relationship within the UK.
Exemptions from registering include charitable trusts, non-taxable trusts for vulnerable beneficiaries and trusts imposed by court order.
HOW is the Trust Registration used
The TRS database is a tool to stop financial crime. Increasingly, banks are beginning to request TRS Certificates to complete their AML checks. Some Trusts may now be required to provide TRS information to their bank annually to keep their bank account open.
Under specific circumstances, certain third parties (e.g., law enforcement) may now access information on the register. However, protections are in place to safeguard personal data.
We are here to help you stay compliant with the latest TRS regulations. If you are unsure whether your trust needs to be registered, or if you need assistance updating your records, please don’t hesitate to get in touch www.burgisbullock.com/contact-us
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