07.11.25

New Registration Requirements for Trustees

Expanding the UK’s AEOI Framework under CRS and FATCA – Enhancing Transparency Across Financial Institutions

The UK Government has introduced a series of amendments to the Automatic Exchange of Information (AEOI) Regulations, implementing the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA).

These changes bring an important shift: all entities classified as Financial Institutions – including Trusts – must now register with HMRC, regardless of whether there are beneficiaries:

• who are not UK tax resident and entitled to receive trust funds, or
• who have received distributions from the trust at the trustees’ discretion.

This expanded registration requirement (in addition to the Trust Registration Service) strengthens HMRC’s oversight of due diligence procedures, reinforcing the UK’s commitment to global tax transparency.

In this piece we set out what the changes mean for Trusts, and the action that needs to be taken by trustees before 31^st December 2025.

Who is affected?

The revised framework extends its scope to include all trusts classified as a Financial Institution who are now subject to mandatory registration.

These fall into two main categories:

1          UK Financial Institutions

Typically, these include:

• trusts with individual trustees where more than 50% of the trust’s income is attributable to investing, reinvesting or trading in financial assets, and
• the trust or its assets are managed by an entity (e.g. a Discretionary Fund Manager).

2          Trustee Documented Trusts

Trusts that are UK Financial Institutions, as above, but also have a Financial Institution as a trustee (e.g. a corporate trustee like Renaissance Trust Corporation Ltd).

These measures bring greater visibility to the movement of assets and financial relationships across jurisdictions.

Who is not affected?

1          Non-Financial Entities

Any trusts that do not fall into one of the above categories. This will include trusts which have been set up with a nominal sum (say £10) and are waiting for funds to be added in the future.

2          Charities/Charitable Trusts

Most charitable organisations will be excluded from the definition of Financial Institution from 1st January 2026 and will therefore be exempt from AEOI registration.

Actions required by those that are affected

The new rules introduce targeted penalties ranging from £100 to £5000 for non-compliance failures so it is vital to take action now.

To prepare for compliance and mitigate exposure to penalties, Trustees of affected institutions should act early:

1. Confirm classification – Determine whether your organisation now falls within the definition of a Financial Institution.
2. Register promptly – Register with HMRC’s AEOI service by 31 December 2025, or 31 January following the calendar year in which the entity becomes registerable.
3. Review due diligence – Ensure that onboarding and monitoring processes align with the updated AEOI obligations.
4. Notify connected parties – Inform relevant individuals (such as holders of the Trust’s financial accounts, controlling persons, etc) that their personal data will be reported to HMRC and may be exchanged internationally.

Regulatory highlights

Mandatory registration

All reportable financial institutions, including Trusts as described above, must register on HMRC’s AEOI platform, details of which are here. We have also published a registration guide. The deadline for existing institutions is 31 December 2025.

Self-certification

Relevant individuals must now provide self-certification information to the trustees. Failure to comply – if deemed careless or deliberate – may result in a £300 penalty.

Notification obligations

Financial Institutions must notify self-certifying individuals that their data will be reported to HMRC and may be shared with overseas authorities. Failure to make this notification carries a £100 penalty per individual, with further daily fines for continuing non-compliance.

Looking ahead

The widening of the AEOI framework represents another step in the evolution of international tax cooperation.

For Trustees, trust and company service providers and other financial institutions, early preparation is essential. Reviewing structures, processes and registration status now will ensure readiness ahead of the 2025–2026 implementation window – and demonstrate continued commitment to transparency and compliance.

How can Renaissance Trust help?

Our specialist team has over 35 years’ experience in the management of Trusts, including advising on all aspects of compliance. If you are a Trustee affected by the change to the AEOI rules, please get in touch to discuss how we can help you with registration and the ongoing administration of the Trust.