Trust Registration Service (TRS): Who Must Register in 2026/27
Most UK trusts must now be registered with HMRC's Trust Registration Service under 5MLD rules. Learn who must register, deadlines, penalties, and exemptions in 2026/27.
Since September 2022, most UK trusts -- not just those with active tax liabilities -- have been required to register with HMRC's Trust Registration Service. This expansion, driven by the Fifth Money Laundering Directive (5MLD), has brought millions of additional trusts within the registration obligation. Many trustees remain unaware they need to act. The penalties for non-compliance are increasing, and HMRC has started using the register as a cross-checking tool against self-assessment returns.
Background: why was TRS expanded?
The original Trust Registration Service was introduced in 2017 as the UK's implementation of the Fourth Anti-Money Laundering Directive (4MLD). At that stage, only trusts with a UK tax liability (income tax, CGT, IHT, SDLT, or LBTT) had to register.
The Fifth Money Laundering Directive (5MLD), implemented in the UK by SI 2020/991, dramatically expanded the scope. From 6 October 2020 for new trusts (and with a transitional deadline of 1 September 2022 for existing trusts), all UK express trusts must register -- whether or not they pay any UK tax.
This means a discretionary family trust holding UK assets with no current income or gains still needs to be on the register.
What is an "express trust"?
An express trust is one that has been deliberately created by a settlor -- typically by a trust deed or a will. It is distinct from:
- Resulting trusts (arising by operation of law when a transfer fails or is imperfect).
- Constructive trusts (imposed by courts).
- Statutory trusts (arising automatically under statute, such as intestacy trusts or trusts imposed by TOLATA 1996).
Only express trusts need to register. Courts and statute-imposed trusts are excluded.
Who counts as a registrable trust?
The following are broadly within scope:
- Discretionary trusts (most family trusts, estate planning trusts).
- Life interest trusts (including those created under a will).
- Bare trusts (where the trustee holds assets for the absolute benefit of one or more named beneficiaries).
- Non-charitable purpose trusts.
- Offshore trusts with UK trustees or UK assets.
Key exemptions from TRS registration
Several categories of trust are exempt:
Registered charities: Trusts registered with the Charity Commission for England and Wales (or equivalent in Scotland/Northern Ireland) are exempt.
Pension scheme trusts: Trusts set up to provide authorised pension scheme benefits are exempt.
Statutory trusts: Trusts arising automatically under statute (e.g., intestacy trusts, or the trust of land in co-ownership under TOLATA) are exempt.
Insurance policies: Trusts holding life insurance policies that pay out only on death or critical illness are exempt, unless the trust has made distributions or the policy is a multiple-life policy.
Pilot trusts under £100 (pre-2020): A pilot trust created before 6 October 2020 with initial trust property of £100 or less is exempt. New pilot trusts created after that date are not exempt.
Child trust funds: These are exempt as they are a statutory savings arrangement.
Registration process and required information
Trustees (or their authorised agent, such as an accountant or solicitor) register using the Government Gateway on the TRS portal. The information required includes:
For the trust itself:
- Trust name.
- Date created.
- Type of trust.
- Country of residence.
For the settlor (the person who created the trust):
- Full legal name.
- Date of birth.
- National Insurance number or Unique Taxpayer Reference (UTR).
- Address.
For each trustee:
- Full name, DOB, NI or UTR, address.
- For corporate trustees: registered company name and number.
For beneficiaries:
- Named beneficiaries: full name, DOB, NI.
- Classes of beneficiaries (e.g. "children and remoter issue of the settlor") if the trust has discretionary beneficiaries who are not yet named.
For any other individuals with control:
- Protectors, appointors, or any person who can direct the trustees.
Ongoing obligations after registration
Registration is not a one-off event. Trustees have continuing obligations:
Annual declaration: For trusts with a UK tax liability, trustees must make an annual declaration on the TRS confirming that the trust details are up to date. This is separate from filing the trust's self-assessment return (SA900).
Updates within 90 days: Any change to the registrable information must be reported within 90 days. Changes include:
- A trustee being added or removed.
- A beneficiary becoming named or their details changing.
- The settlor dying or changing address.
- Significant changes to the trust's assets.
- The trust becoming or ceasing to be tax-relevant.
Penalties for non-compliance
HMRC set out the penalty regime in its published guidance:
- First failure to register or update: £100 fixed penalty.
- Second failure: £200 fixed penalty.
- Third or subsequent failure, or deliberate/concealed non-compliance: Up to £300 or 5% of the trust's tax liability (whichever is the greater).
HMRC has indicated it will take a proportionate approach and initially focused on guidance rather than enforcement. However, as awareness of TRS obligations has spread and the deadlines have passed, HMRC is beginning to issue penalties to trustees who have failed to register despite clear obligations.
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Open Inheritance Tax calculatorFrequently asked questions
What is the Trust Registration Service?
The Trust Registration Service (TRS) is HMRC's online register of UK trusts. It was originally introduced in 2017 for trusts with a UK tax liability. Since 2022, the scope has expanded significantly under the Fifth Money Laundering Directive (5MLD) to include most UK trusts regardless of whether they have a tax liability.
Which trusts must now register on the TRS?
All UK express trusts (trusts deliberately created by a settlor, not arising by operation of law) must register unless a specific exemption applies. This includes discretionary trusts, life interest trusts, bare trusts, and many family trusts even if they have no income or assets. Express trusts with a UK tax liability have the broadest registration obligation.
When was the 5MLD expansion deadline?
The expanded TRS registration under 5MLD applied from 6 October 2020 for new trusts and September 2022 for existing trusts. Existing trusts that were not on the register had until 1 September 2022 to register under the expanded rules. New trusts must now register within 90 days of creation.
What are the penalties for failing to register?
HMRC can issue penalties for late registration. The initial penalty is £100 for a first late registration, rising to £200 for a second failure, and up to £300 or 5% of the tax liability (whichever is higher) for deliberate non-compliance. HMRC has indicated a light-touch approach during the initial rollout but enforcement is increasing.
What information must be provided to register a trust?
The TRS requires details of the trust itself (name, date of creation, type), the settlor (name, date of birth, National Insurance number or UTR), all trustees (name, DOB, NI or UTR, address), all named beneficiaries (or a description of the class of beneficiaries), and any 'other individuals with control' over the trust (protectors, appointors, etc.).
Are bare trusts for children exempt from TRS registration?
Bare trusts holding assets for minors where the child will become absolutely entitled at 18 are not automatically exempt under the basic rules. However, certain specific bare trusts are exempt -- particularly a bare trust that is a 'statutory trust' (e.g. arising from intestacy) or a trust imposed by a court order. A parent-held bank account or investment ISA for a child that is held as a bare trust may still need to register.
Are charitable trusts exempt?
Yes. Charitable trusts registered with the Charity Commission or HMRC are exempt from TRS registration. Unregistered charities with annual income under £5,000 may still be exempt provided they are formally constituted as a charity.
Are pilot trusts exempt?
Pilot trusts created before 6 October 2020 with assets under £100 are exempt. A pilot trust created on or after 6 October 2020 must register regardless of its asset value -- the old 'pre-October 2020 pilot trust' exemption does not apply to new ones.
Must trustees update the TRS register when information changes?
Yes. Trustees must update the TRS register within 90 days of any change to the trust's registrable information -- including changes to trustees, beneficiaries, settlor details, and the trust's assets or tax position. Annual declarations are also required for trusts with a tax liability.
Who can access the TRS register?
The TRS register is not public. Access is limited to law enforcement agencies, regulated businesses conducting anti-money-laundering due diligence (who have a legitimate interest), and the trust itself. However, persons with a legitimate interest can request disclosure in specific circumstances.
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