We help trustees protect family assets without legalese. Since 2017 the Trust Registration Service (TRS) has made registration and reporting part of life for most UK trusts. The TRS supports tax reporting and anti‑money‑laundering checks, and a missed duty can lead to a fixed £5,000 penalty in some cases.
We will explain what these charges are, why they happen, and how trustees can avoid an expensive surprise. Our aim is practical and friendly. Many people become trustees through family duty, not training, so our guidance stays simple.
Good compliance means knowing if a trust must register, gathering the right details, and keeping records up to date. Penalties usually stem from missed deadlines, late updates, or ignoring correspondence. If you already have a problem, we set out clear next steps and how to challenge a charge where it feels unfair.
For more detail on avoiding fines, see our practical guide and a trustee’s step‑by‑step resource.
Avoiding TRS registration fines · Register as a trustee: a simple
Key Takeaways
- Register relevant trusts on the TRS and keep details current.
- Missed deadlines and ignored letters commonly trigger fines.
- Collect beneficiary and trustee details early to avoid stress.
- Small errors can be fixed; act quickly to reduce risk of a charge.
- We offer clear, plain‑English steps to move from worry to action.
Trust Registration Service requirements trustees must meet
Most family arrangements need checking for registration — it’s easier than it sounds. We set out what the register is, who must sign up and the dates you should diarise.
What the registration service is and why it exists
The trust registration service is an online register run to improve tax transparency and support anti-money‑laundering checks. It helps authorities spot where a tax charge may arise and where further checks are needed.
Which arrangements must register
The vast majority of UK arrangements and settlements are affected. Taxable cases always need recording. Since 2020 (5MLD) many non-taxable trusts also fall within scope unless specifically excluded.
Key deadlines and time limits
Registration generally had to happen within 90 days of creation for new arrangements. Older cases were expected to be on the register by 1 September 2022. Taxable entries need an annual confirmation by 31 January and all changes updated within 90 days.
| Type | Must register? | Key deadline | Ongoing duty |
|---|---|---|---|
| Taxable | Yes | Within 90 days | Annual return by 31 January |
| Non-taxable (most) | Often | Within 90 days or by 1 September 2022 | Update changes within 90 days |
| Excluded (Schedule 3A) | No | N/A | Keep records to show exclusion |
If you’re unsure whether an arrangement must register, use our practical registering guide to check dates and the exact requirement. We recommend diarising the relevant date and updating details within days of any change.
How to prevent hmrc trust penalties through timely trust registration and updates
Start by checking whether your arrangement must be on the register or is safely excluded — that single check saves time and worry.
Check whether your trust is excluded or must register
Confirm eligibility first. This avoids wasted effort and reduces the risk of a failure register issue.
Gather the trust details the TRS expects
Collect the names, dates, addresses, tax references and asset summary in one place. Having full details avoids repeated stops in the registration process.
Set up access using an Organisation Government Gateway ID
Use an Organisation ID, not an Individual ID. In practice you may need a separate Organisation ID for each trust you manage.
Register a trust on the online portal and record the submission date
Complete the online registration, save a PDF copy and note the submission date. That date matters if a question arises later.
Keep TRS information accurate by updating changes within 90 days
Any change of trustee, beneficiary, assets or address should trigger an update within 90 days. For taxable trusts, plan the annual confirmation by 31 January each year.
Avoid common non-compliance triggers
“Act quickly on changes and keep one clear file — it stops most nudge letters.”
Common causes of a compliance letter include long gaps since creation, missing updates after a change and inconsistencies with tax filings. Make TRS maintenance a simple household routine and you will reduce risk.
How HMRC applies trust penalties and what to do if you receive a penalty notice
A posted penalty starts a strict timetable — knowing each step protects you and other trustees.
What counts as an offence
We treat an offence as one of three things: failing to register when required, registering late, or not updating service details after a change.
How the fixed £5,000 charge can arise
The charge can be £5,000 per offence. Decisions are taken on a case‑by‑case basis, so repeated failures risk multiple fines.
When a charge may not be imposed
If the failure was not deliberate and you correct the details within the time limit set, a charge may not be applied.
Immediate steps when a notice arrives
- Confirm exactly what the notice says is missing.
- Update the online service and save proof of the change.
- Keep dated evidence and tell co‑trustees straight away.
Challenge and payment routes
Request a review within 30 days with supporting information. HMRC usually replies in about 45 days and the penalty is not payable during a review. If needed, appeal to the independent tribunal within 30 days.
“Act quickly, correct the record and keep evidence — that often resolves the case.”
Practical payment options include Faster Payments, BACS/CHAPS, Direct Debit, card or cheque. Trustees are personally liable, so keep proof of settlement for your records.
Conclusion
Small acts now — register, update, diarise — stop small problems becoming major ones.
Most family trusts need attention under the registration service. The simple message is clear: register on time, update within 90 days of any change, and diarise the 31 January annual declaration for taxable cases.
Keep TRS details accurate and break the process into steps. Treat the register like a home safety check: verify who is named, record the facts, and update them when things change.
We recommend our step‑by‑step guide to registering a trust if you need a calm, practical route through the registration service. Act now to protect the people the arrangement was set up to help.