The government is introducing significant changes to the Trust Registration Service. The aim of these changes is to improve transparency, whilst reducing unnecessary administration for lower-risk trusts.
Trustees should review their current arrangement carefully, as some trusts which were previously outside the scope of registration may now be required to register.
Trusts that own UK property
One of the most important changes affects non-UK resident trusts that own UK property. Under previous rules, non-UK trusts generally only needed to register if they acquired UK land or property on or after 6 October 2020. The new rules widen the scope so that certain non-UK trusts holding UK property acquired before that date may also be required to register with the TRS. This means trustees of long-standing overseas trusts should revisit their obligations, even if they have never previously had to engage with the register.
Trusts created after a death
The changes also bring greater consistency to trusts that arise following a death. Currently, trusts created through a will benefit from a two-year grace period before registration becomes necessary. However, other trusts that arise on death, such as certain co-ownership trusts or deeds of variation, have often been subject to a much shorter 90-day registration deadline. Under the revised rules, most death-related trusts are expected to receive the same two-year grace period. This should make administration easier for families, executors and professional advisers dealing with probate and estate administration
De Minimis exemption
Another notable development is the introduction of a new exemption for smaller, lower-risk trusts. Often referred to as a “de minimis” exemption, this measure is intended to reduce the compliance burden for trusts that hold relatively modest assets and present a low risk from an anti-money laundering perspective.
Trusts that have ever exceeded £10,000 in value or own UK land do not qualify for this exemption. There are other exclusions, so it is important to carefully consider the detailed qualifying conditions. Broadly, the change should be viewed as a positive one with an overall objective to ensure that trustees of small, low risk, trusts are not caught by disproportionate reporting requirements.
What does this mean for the current landscape?
The wider reforms reflect a more targeted approach to trust regulation. On one hand, HMRC is tightening requirements around trusts considered higher risk, particularly those involving overseas ownership of UK property. On the other hand, it is easing obligations for bereavement-related and low-value trusts where the compliance burden may outweigh the benefits. Trustees should not assume that existing arrangements remain unaffected; instead, they should review registration obligations, confirm whether any new exemptions apply, and ensure that trust information remains accurate and up to date. Early action will help avoid penalties and ensure compliance as the revised Trust Registration Service rules take effect.
Trust Registration Service (TRS): Frequently Asked Questions
What is the Trust Registration Service (TRS)?
The Trust Registration Service is HMRC’s online register of trusts. It was introduced to improve transparency and help combat money laundering by requiring trustees to provide details about the trust, its assets, trustees, settlors and beneficiaries.
What are the main TRS changes trustees need to know about?
The key changes include expanding registration requirements for certain non-UK trusts holding UK property, extending registration deadlines for many trusts created following a death, and introducing exemptions for some low-risk, low-value trusts.
Will more non-UK trusts need to register?
Yes. Under the new rules, certain non-UK trusts that acquired UK land before 6 October 2020 may now need to register if they continue to hold that property. Previously, many of these trusts were outside the scope of the TRS.
How are registration deadlines changing for trusts created after a death?
Most trusts arising on death are expected to benefit from a two-year registration grace period. This aligns them with trusts created through a will and gives executors and families more time to deal with estate administration before considering registration requirements.
Are there any new exemptions for small trusts?
Yes. The government is introducing a “de minimis” exemption for certain low-value, low-risk trusts. The aim is to reduce the administrative burden on trustees where the trust presents minimal money laundering risk.
What happens if a trust that was previously exempt now falls within the new rules?
Trustees should review the trust’s circumstances as soon as possible. If the trust now falls within the TRS requirements, registration may be necessary and trustees will need to ensure all relevant information is submitted accurately and on time.
Will trust information be available to the public?
No. TRS information is not publicly available. However, certain information may be shared with authorities or third parties that can demonstrate a legitimate interest, particularly in relation to anti-money laundering investigations.
What should trustees do now?
Trustees should review existing trust arrangements, check whether they are affected by the new rules, verify that trust records are up to date, and seek professional advice where necessary to ensure compliance.
What are the risks of failing to register a trust?
Failure to comply with TRS requirements can result in penalties from HMRC and increased scrutiny of the trust’s affairs. Trustees should therefore ensure they understand their obligations and meet any applicable registration deadlines.
If you are unsure whether your trust is affected by the Trust Registration Service (TRS) changes which took effect from 30 June 2026, or whether it now needs to be registered, Tees can help. Our trusts specialists, including lawyers and tax accountants, can review your trust and advise on your registration obligations, helping you stay compliant while avoiding unnecessary administration. Speak to Tees today to discuss how the changes may affect you.
