The Trust Registration Service (TRS) is HMRC’s online register of the beneficial owners of most UK trusts, introduced to meet anti-money-laundering rules. Since 2022 the requirement extends well beyond trusts that pay tax -- most express trusts, including many family and property arrangements, must register even if they generate no income at all. This guide explains which trusts are caught, the 90-day registration window, ongoing update duties, and the penalties for getting it wrong in 2026/27.
Which Trusts Must Register
Since 1 September 2022, the TRS requirement extends to virtually all UK express trusts -- trusts deliberately created by a settlor, whether by will, deed, or declaration -- regardless of whether the trust pays any UK tax. This is a major expansion from the old rule, which only required registration if a trust had a tax liability.
Common trusts that must register include:
Discretionary and interest-in-possession trusts holding investments or property.
Many bare trusts, including some set up informally for children.
Trusts created in a will that continue beyond the estate administration period (typically more than two years after death).
Property held on trust by co-owners in unequal shares (in some circumstances).
Certain trusts are excluded, such as trusts imposed by court order, some pension scheme trusts, and certain charitable trusts -- but the exclusion list is narrow, so most family and estate planning trusts are within scope.
The 90-Day Registration Deadline
A taxable trust must register within 90 days of becoming liable for UK tax (or by 5 October following the tax year in which it first becomes taxable, if later). A non-taxable express trust that existed on or after 6 October 2020 should already be registered -- new non-taxable trusts must register within 90 days of being created.
Trustees must also keep the register up to date, notifying HMRC of changes to trustees, beneficiaries or trust details within 90 days of the change, and confirming annually (where the trust has a tax liability) that the details are still accurate as part of the Self Assessment trust tax return process.
Penalties for Late or Missing Registration
HMRC’s stated approach for first-time failures is generally not to charge an automatic penalty where trustees can show they took reasonable care, instead issuing a nudge letter or warning. However, HMRC can charge a fixed penalty of £100 or more for continued failure to register, and deliberate non-compliance can be treated more severely, particularly where it forms part of wider tax non-compliance.
Beyond financial penalties, an unregistered trust can face practical problems -- banks, solicitors and other regulated businesses increasingly ask for proof of TRS registration before opening accounts or acting on transactions involving the trust.
How Trustees Register
The lead trustee registers the trust online via the Government Gateway, providing details of the settlor, trustees, and beneficiaries (or classes of beneficiary, for discretionary trusts), along with the trust’s assets. Once registered, the trust receives a Unique Reference Number.
Professional agents such as solicitors or accountants can register and maintain the trust on behalf of trustees, but legal responsibility for accuracy and timely updates always sits with the trustees themselves.
Frequently Asked Questions
Do bare trusts have to register with the TRS?
Many do. Since the 2022 expansion, bare trusts are within scope unless a specific exclusion applies -- for example, certain bare trusts holding assets for a minor that fall under specific statutory exemptions. Because bare trusts (such as informal accounts held "for" a child) are common and easy to overlook, trustees should check the current exclusions carefully rather than assume they are exempt.
Does a trust with no income or gains still need to register?
Yes, in most cases. Since September 2022, non-taxable UK express trusts generally must register even if they hold assets that produce no income and have made no gains -- the requirement is about identifying beneficial ownership for anti-money-laundering purposes, not about tax liability alone.
What information does the TRS ask for?
Trustees provide details of the settlor(s), all trustees, and beneficiaries (named individuals, or classes such as "grandchildren of the settlor" for discretionary trusts), plus a description of the trust assets. For trusts with a tax liability, financial details are also reported through the annual Self Assessment trust return.
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How quickly must changes be reported?
Trustees must update the register within 90 days of a relevant change, such as a new trustee being appointed, a beneficiary becoming entitled to a distribution, or a change of trust assets. Missing this window can itself trigger a penalty even if the original registration was on time.
Who can see the information on the Trust Registration Service?
The register is not fully public. HMRC, law enforcement and other authorities have access, and certain third parties -- such as banks and other regulated businesses carrying out due diligence, or people who can show a "legitimate interest" -- can request limited information in defined circumstances.
Do wills automatically create a trust that needs registering?
Not always, and timing matters. Trusts arising simply from estate administration (the executor holding assets before distribution) do not usually need to register while administration is ongoing, but if a trust continues beyond that period -- for example, a life interest trust for a surviving spouse, or a trust for minor beneficiaries -- it will typically need to register once it becomes an ongoing trust.
Can I register a trust myself or do I need a solicitor?
Trustees can register directly through HMRC’s online service themselves; a solicitor or accountant is not legally required, though many trustees use a professional adviser given the complexity of identifying beneficiaries and assessing exclusions correctly.
What if I discover an old trust was never registered?
Register it as soon as possible and be prepared to explain the delay if HMRC asks. Coming forward voluntarily, before HMRC identifies the failure itself, generally leads to a more lenient response than being caught through a compliance check.
Does registering with the TRS mean the trust will pay more tax?
No -- registration itself does not create or increase a tax liability. It is a reporting and transparency obligation. Any Income Tax, Capital Gains Tax or Inheritance Tax due from the trust is calculated under the normal trust taxation rules, independently of the registration requirement.
Do trusts based outside the UK ever need to register with the TRS?
Yes. A non-UK trust can fall within scope if it has at least one UK trustee and receives UK income or owns UK assets such as property, or if it acquires UK land or property directly, even where none of the trustees are UK resident. Trustees of overseas arrangements with any UK connection should check whether registration applies rather than assume it only concerns wholly domestic trusts.
Disclaimer: This guide reflects Trust Registration Service rules as they apply in 2026/27. Registration requirements and exclusions can change; always check the current gov.uk guidance for your specific trust. This guide is for general information only and is not professional advice. Consult a qualified adviser and refer to gov.uk for current official guidance before relying on any treatment.
