Trust Registration Service: who must register a trust

What the register is and why it exists

The Trust Registration Service is HMRC's online register of UK express trusts and certain non-UK trusts with a UK connection. It was introduced for anti-money laundering purposes and extended in 2022 to cover trusts with no tax liability. Registration is a legal duty on trustees, not a tax filing. You register the trust because the law requires it, not because a tax return is due.

All UK resident express trusts must register even if they have no tax liability, unless they are excluded from registration as a Schedule 3A trust. Trusts that need to obtain a Unique Taxpayer Reference, for example to report non-resident Capital Gains Tax, must also register. Non-UK resident express trusts with certain links to the UK must register, such as those that acquire land or property in the UK after 6 October 2020. A UK resident trust must register if it is liable for UK taxes on UK assets or income, and a non-UK resident trust must register if it becomes liable to those taxes on UK assets or income.

The register is not fully public. Access to information about a trust is subject to a legitimate interest test under the Money Laundering Regulations. That means banks, solicitors and other regulated firms can check the register for their own compliance, but the general public cannot browse trust details freely.

Who must register, in a table

The table below sets out the main categories. Where the answer is yes, treat it as yes unless a specific exclusion applies to the trust.

Bare trusts are express trusts and remain within the general scope of the Trust Registration Service. The 2026 changes do not create a specific exemption for bare trusts as a category, although a bare trust could qualify for the low-value exemption if it meets the conditions. A trust which was exempt from registration as an express trust would still need to register as a taxable trust if it incurred a tax liability.

What changed on 30 June 2026

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, SI 2026/621, came into force on 30 June 2026 and brought the most significant changes to the Trust Registration Service since the 2022 expansion. The headline change is a new low-value trust exemption. Under the 2026 changes a low-value trust exemption applies where a set of conditions is met, including that annual income from the trust does not exceed 5,000 pounds and that non-financial assets such as jewellery or art are worth 2,000 pounds or less.

Losing any qualifying condition triggers a full registration obligation, and the trust must then be registered within 90 days. That means trustees relying on the exemption need to monitor the values. If income rises above 5,000 pounds in a year, or if non-financial assets such as jewellery or art rise above 2,000 pounds, the exemption falls away and the clock starts. The same applies if any other qualifying condition is no longer met.

The exemption is not a permanent status. It is a set of conditions that must continue to be satisfied. A trust that qualifies today may not qualify next year, and the duty to register within 90 days of losing a condition rests on the trustees. Keeping a simple record of income and asset values is the practical way to stay on top of it.

The accidental trustee problem

Many people are trustees without knowing it. A will trust created on death, a life insurance policy written in trust, a property held for someone else. These arrangements can make you a trustee even though you never filled in a form or thought of yourself as one. The trust exists because the documents say so, and the registration duty follows the trust.

A trust holding a protection policy is an excluded express trust and does not need to be registered immediately. Where the trust receives the policy pay-out following the death of the person covered, the trustees have two years from that death to distribute the funds before registration is required. If the funds have not been distributed by the end of that period, the trust must register from that point.

Where a benefit is paid to trustees on another kind of claim, such as diagnosis of a critical illness or surrender of a policy, HMRC has confirmed the trust must be registered within 90 days of the claim being paid. The two-year window applies to a pay-out following death, not to these other claims. If you are named as a trustee on a policy, check which situation applies before assuming no action is needed.

What registration involves and the annual declaration

Registration requires information about the trust and the people connected to it. You need the trust name and deed date, the settlor, the trustees and the beneficiaries. For taxable trusts you also provide the tax data. The register is built from these details, and they must be accurate when submitted.

Trustees must update the Trust Registration Service within 90 days of changes to the trust details, such as a change of trustee, beneficiary, assets or address. This is a continuing duty, not a one-off task. If a trustee steps down or a new beneficiary is added, the register must reflect it within the 90 day window.

Trustees must declare annually that the information held on the register remains accurate, even where there have been no changes. The annual declaration is a positive confirmation, not a passive one. Missing it can leave the register out of date in HMRC's eyes even if nothing about the trust has actually changed.

Penalties and the practical consequences

HMRC has the power to impose a fixed penalty of 5,000 pounds for non-compliance where a trust is not registered or the register is not kept up to date within the time limit, and penalty charges are raised on a case-by-case basis. HMRC treats failing to register, registering late and failing to update as separate offences. That means more than one penalty can arise from the same trust if the failures are distinct.

The point most guides miss is that banks, solicitors and other regulated firms check the register for their own compliance. An unregistered trust causes problems when selling property or opening an account, often before HMRC becomes involved. A solicitor acting on a property sale may ask for proof of registration, and a bank may do the same when an account is opened in the trust's name. The practical blockage can arrive long before any penalty notice.

For trustees, the safe approach is to treat registration and updating as part of the ordinary administration of the trust. Keep the deed, the trustee details and the beneficiary details together. Diarise the annual declaration. Note the 90 day windows for tax liability, changes and loss of any low-value exemption condition. That way the register stays accurate and the trust does not create avoidable problems at the point when it needs to act.

Related coverage on Kael Tripton: Writing life insurance in trust: how it avoids inheritance tax and probate delays, Inheritance tax: married couples vs unmarried partners and the spouse exemption, Free Wills Month: who qualifies, what is free and what is not, Mayors Get Power to Charge a Visitor Levy on Hotel Stays: What UK Holidaymakers Will Pay, UK Life Insurance in Trust: IHT Benefit Explained.

Frequently asked questions

Do all UK express trusts need to register with HMRC?

All UK resident express trusts must register even if they have no tax liability, unless they are excluded from registration as a Schedule 3A trust. Trusts that need to obtain a Unique Taxpayer Reference, for example to report non-resident Capital Gains Tax, must also register.

What is the deadline for registering a trust?

Trusts must be registered within 90 days of the trust becoming liable for tax, or on or before 1 September 2022, whichever is later. Non-UK trusts that held UK land before 6 October 2020 and continue to do so must register by 1 September 2027, and GOV.UK notes that the Trust Registration Service currently will not let these trusts register.

What changed on 30 June 2026?

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, SI 2026/621, came into force on 30 June 2026 and brought the most significant changes to the Trust Registration Service since the 2022 expansion. Under the 2026 changes a low-value trust exemption applies where a set of conditions is met, including that annual income from the trust does not exceed 5,000 pounds and that non-financial assets such as jewellery or art are worth 2,000 pounds or less.

What happens if a trust loses the low-value exemption?

Losing any qualifying condition triggers a full registration obligation, and the trust must then be registered within 90 days. Trustees relying on the exemption need to monitor the values.

Does a trust holding a protection policy need to register?

A trust holding a protection policy is an excluded express trust and does not need to be registered immediately. Where the trust receives the policy pay-out following the death of the person covered, the trustees have two years from that death to distribute the funds before registration is required. If the funds have not been distributed by the end of that period, the trust must register from that point. Where a benefit is paid to trustees on another kind of claim, such as diagnosis of a critical illness or surrender of a policy, HMRC has confirmed the trust must be registered within 90 days of the claim being paid.