17.07.26

Changes to HMRC’s Trust Registration Service (TRS): What UK Trustees Need to Know

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 came into force on 30th June 2026 following a lengthy consultation period. Amongst other things, the Regulations make a number changes to HMRC’s Trust Registration Service (TRS) that Trustees of UK Trusts should be aware of.

What is the TRS?

HMRC’s TRS was established in 2017 following The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The TRS is a record of Trusts and their Beneficial Owners (Settlors, Trustees and Beneficiaries).

Since its introduction, the TRS has evolved significantly. With a few exceptions, Trusts were required to register by 2022. Trusts are registered on the TRS as either Taxable Trusts, which are given a Unique Taxpayer Reference (UTR), or Non-Taxpaying Trusts, which are given a Unique Reference Number (URN).

Failure to register a Trust on the TRS when registration is required can result in financial penalties of up to £5,000. Penalties may also be imposed for failing to keep the information on the register up to date, with changes being required within 90 days. Trustees should ensure that their Trust is correctly registered to comply with the requirements and avoid penalties.

Low Value Trusts: Exclusion From Registration

The new Regulations adopt an exclusion for low value Trusts. Before 30 June 2026, almost all express Trusts were required to register on the TRS, unless they met certain exemptions. In some cases this was seen to be onerous, particularly where a Trust was required to register even though it only held a sum of £10 cash.

Since 30 June 2026, Trusts which meet the following criteria will no longer need to register on the TRS:

1. The Trust does not hold any interest in land in the UK
2. The Trust holds assets of appreciable worth less than £2,000
3. The Trust has not held property with a value exceeding £10,000 since it was created
4. The Trust does not have an annual income exceeding £5,000

Trustees should be aware that the exclusion does not apply where the Settlor has created  other express Trusts which are excluded under the Regulations.

In contrast, all Trusts with assets that generate income and gains must register as taxable trusts. Further guidance on this can be found here: https://www.gov.uk/trusts-taxes/trusts-and-income-tax. The £500 income tax limit, which is shared amongst all Trusts created by the same person, often confuses people because the income tax rules and the TRS rules are entirely separate.

Impact on Disabled Person’s Trusts

Disabled Person’s Trusts continue to be exempt from registration under the Regulations until such time as they have a liability to tax. The Regulations therefore are less likely to affect Disabled Person’s Trusts.

Deeds of Variation: Change to the Registration Deadline

A Deed of Variation can be used to vary an individual’s entitlement under a Will or an Intestacy. For example, an individual may use a Deed of Variation as a mechanism to redirect an inheritance that they are due to receive into a Trust for their children.

Prior to 30 June 2026, Trusts created by Deeds of Variation were required to register within 90 days of creation. This did not align with the position that applies to other Trusts created on death, such as Will Trusts, that remained exempt from registration for the first two years following death. The disparity between the two registration deadlines was widely criticised.

The Regulations have unified the position and have now increased the registration deadline for Trusts created by Deeds of Variation to two years following the date of death, mirroring the position for Trusts created by Will. This change has been welcomed by critics who highlighted the previous inconsistency.

Action Points for Trustees

This serves as a reminder to Trustees to consider whether their Trust is correctly registered with HMRC and seek professional advice where there is uncertainty.

It is also important for Trustees to ensure that the information on the TRS is correct and up to date to ensure that they do not fall foul of HMRC’s requirements.

Trustees of Taxable Trusts should ensure they are completing annual declarations to declare that the TRS is up to date.

How can we help?

These changes serve as a reminder to Trustees that the regulatory landscape is constantly changing and evolving. Trustees may miss important updates and may therefore inadvertently miss deadlines and risk receiving penalties for non-compliance.

The team at Renaissance Trust are experts in Trust management and administration. We can also act as a Corporate Trustee to give Trustees the peace of mind that their Trust is being managed with the highest level of expertise.

For advice and guidance on TRS requirements and obligations or to discuss any of our other services, please get in touch with a member of our specialist team.