We know trustees feel pressure when handling estate matters after a death or during a sale. We’ll explain what HMRC expects in plain language and show practical steps you can follow today.
This guide sets out the difference between a simple record kept for transparency and a taxable arrangement that needs ongoing tax reporting. We use clear examples so you can match forms to your documents.
We outline key people — settlor, trustee and beneficiary — and how the Trust Registration Service fits into day-to-day administration for family assets. We also flag common pitfalls, such as choosing the wrong account type, missed deadlines or missing ID details.
Practical next steps include gathering essential details and using the online service to register trust records correctly. If you need a straightforward walkthrough, see our practical guide to register trust.
Key Takeaways
- We simplify HMRC steps so trustees can act with confidence.
- Some trusts must report tax; others simply appear on the register.
- Gather correct identity and asset details before you start.
- Use the online service and keep records up to date.
- Avoid common delays by picking the right account type early.
- Work methodically when time is tight after a loved one’s death.
What the Trust Registration Service is and why it matters
An online service holds recorded information to improve transparency and help firms run anti-money‑laundering checks. We explain what this means in plain terms and why you should take it seriously.
How TRS supports anti-money laundering compliance
TRS is the government’s online register for express arrangements. It helps banks, solicitors and other relevant people confirm who runs an estate before they act.
This reduces fraud and makes ordinary checks faster. It is not just an accountant’s tool; it affects day‑to‑day dealings with professionals.
Outcomes: URN for non-taxable trusts or UTR for taxable trusts
After you use the registration service, HMRC issues a number to the record. Non‑taxable trusts get a URN. Taxable trusts receive a UTR. These usually arrive within 15 working days.
Treat the number like sensitive paperwork. It links the arrangement to official letters and online accounts.
What “managing your trust’s details” means in practice
Manage Your Trust’s Details lets you view and update trustees, beneficiaries and assets. You can also download proof to share with banks or advisers.
Keeping information current avoids delays when new banks or solicitors ask for evidence.
| Purpose | Who uses it | Typical outcome | Action for trustees |
|---|---|---|---|
| Transparency | Banks, solicitors, agents | URN or UTR issued | Save and secure the number |
| AML checks | Relevant persons | Faster verification | Update details when changes occur |
Do you need to register your trust with HMRC?
The core rule is simple: UK express arrangements usually need to be recorded, even when no tax is due.
UK express trusts that must register even with no tax liability
Most UK express trust structures are in scope unless an exclusion in Schedule 3A applies. An express trust means the arrangement was set up deliberately, often with a deed or clear terms.
Non-UK express trusts: UK property and UK business relationships
Non‑UK arrangements must register if they acquire UK property, or if one trustee is UK‑resident and the arrangement enters a UK business relationship. Practical examples include buying a UK holiday let or opening an investment account with a UK provider.
When a trust becomes registerable because it’s liable to tax
Trusts must be recorded when they become liable tax‑wise. Common triggers are Income Tax, Capital Gains Tax, Inheritance Tax, SDLT/SDRT, LBTT and LTT. A person acting as trustee should check the deed and asset paperwork to spot these triggers.
| Trigger | What it means | Practical example |
|---|---|---|
| UK property | Brings non‑UK arrangement into scope | Family trust buys a holiday let |
| UK‑resident trustee + business | Business relationship with UK provider | Opening investment account |
| Tax liability | Any taxable event for the arrangement | Capital gain on sale of shares |
What to do next: check the deed, list assets and follow our simple decision path or seek advice if unclear.
Schedule 3A excluded express trusts and other common exemptions
We walk through the main exclusions under Schedule 3A so you can spot when an arrangement may not need registration.
Will arrangements closed within two years
Will trusts that are fully wound up within two years of death are usually exempt. This helps families avoid extra steps while probate is finalised.
Pension scheme and life policy arrangements
Trusts holding assets for a UK registered pension scheme are excluded where they only hold pension funds.
Life insurance policies held in trust that pay only on death, illness or disability are normally exempt too.
Co-ownership for tenants in common and pilot rules
Co-ownership where shares reflect who owns part of a property — often called a held trust arrangement — is exempt if it only records ownership between tenants in common.
Pilot trusts created before 6 October 2020 with under £100 in value are also excluded unless tax becomes due.
Keep this in mind: an exemption ends if the arrangement acquires tax liability. Keep simple records and clear information to show why you relied on an exclusion. For practical help and agent guidance see our agent guide.
| Exemption | Typical condition | When it fails |
|---|---|---|
| Will trusts | Closed within two years | Still open after two years or tax arises |
| Pension scheme | Holds only pension scheme assets | Other taxable assets added |
| Life policy | Pays only on death/illness | Policy creates taxable income |
| Co-ownership | Reflects tenants in common shares | Arrangement creates wider powers over property |
Deadlines and timing rules trustees need to follow in the UK
Timing matters for every trustee. Different dates apply depending on when the trust created and whether tax is due. We set out the rules so you can act with confidence.
Registering non-taxable trusts within 90 days
Non-taxable trusts formed after 6 October 2020 must be recorded within 90 days from creation or from the date they become liable to tax. That means you should act promptly once documents are final.
Taxable trusts: how deadlines vary by creation date
For taxable trusts, the deadline depends on when the arrangement began. Trusts created on or after 6 April 2021 normally need recording within 90 days of becoming liable to tax.
If the arrangement started before 6 April 2021, trustees may face older cut‑offs. These include 5 October for a first‑time Income Tax or Capital Gains Tax liability, or 31 January for later liabilities or other taxes.
Key cut-offs trustees commonly miss
Trustees often miss dates because they assume “no tax” means “no action”, or they wait for probate paperwork. If two deadlines apply, always meet the earlier one.
“Register promptly, gather required information, and seek advice if you think penalties may follow.”
| Situation | Deadline | Practical tip |
|---|---|---|
| Non‑taxable trusts after 6 Oct 2020 | 90 days from creation | Set a diary reminder for the 90th day |
| Taxable trusts created on/after 6 Apr 2021 | 90 days from tax liability | Log the liability date in your checklist |
| Trusts created before 6 Apr 2021 | 5 Oct or 31 Jan depending on liability | Follow the earlier cut‑off and link to Self Assessment cycle |
What to do if you’re late: collect the information, complete the registration without delay and get professional help to reduce penalty risk.
Information you must gather before registering a trust
We recommend preparing a short checklist before you log in. This saves time and stops errors that cause delays.
Core details you will need include the arrangement name, the creation date and confirmation it is an express arrangement. Keep the deed or document pages to hand so the name and date match exactly.
Lead trustee data should include full name, date of birth, National Insurance number for UK nationals or passport details for non‑UK nationals, current address, phone, country of residence and nationality.
For settlors, trustees, protectors and beneficiaries gather name, date of birth, residence and nationality. Where asked, have NI numbers or passport details ready. Small mismatches, such as a missing middle name, can cause queries later.
UK property details must list addresses or plot descriptions and the current value. This matters when property forms part of the assets trust.
For taxable arrangements prepare totals for money, company shares (company name, number, class and value), business interests (name, description, address, value) and other assets (description and value).
Finally, store copies of the deed, identity documents and asset schedules in a secure folder so trustees can access the information later.
Government Gateway setup for trustees using the TRS
Start calmly: set up Government Gateway, note the access code rules and store your ID securely.
We walk you through the steps in plain language so you do not feel rushed. To claim and manage the TRS you must create sign‑in details with an email access code. That code expires after 30 minutes. You then receive a 12‑digit Government Gateway ID. Keep this safe — it is the key to the account long term.
Choose an “organisation” account when acting for the arrangement, even if you are an individual trustee doing the work at home. This prevents access problems later and links correctly to the TRS record.
Set up two‑factor security by text or phone. Ensure your phone number can receive codes. Enter matching personal details carefully. Three incorrect attempts will lock the system for 30 minutes.
- Have National Insurance details ready in case the system asks for matching data.
- Store the Gateway ID and email used to sign up in a secure folder.
- If locked out, wait 30 minutes then retry with exact details.
| Step | What to expect | Key action | Tip |
|---|---|---|---|
| Create sign‑in | Email access code (30 mins) | Use an active email | Start when you can focus |
| Choose account | 12‑digit Gateway ID | Pick “organisation” | Store the ID securely |
| Security | 2‑factor codes by text/phone | Confirm phone can receive texts | Avoid three mismatches |
Need more help? See our clear guide to unlock wider benefits here: unlock the benefits of a UK.
Registration of a trust hmrc: step-by-step on the Trust Registration Service
Begin on Gov.uk. Choose the correct record type at the start so you do not need to redo entries later. We guide you through each page and the small checks that matter.
Starting the online service via Gov.uk and selecting the right trust type
Open the TRS path and pick the category that matches your deed. The online route is clear but choices must mirror your paperwork.
Entering lead trustee details accurately, including National Insurance number
Enter the lead trustee name, date of birth and national insurance where asked. Spelling and dates must match ID to avoid delays.
Adding settlors, trustees and beneficiaries (including classes of beneficiaries)
Add people connected to the arrangement: settlors, trustees and beneficiaries. Use classes (for example “children and remoter issue”) when allowed.
Declaring UK tax liabilities that trigger registration
Declare any income tax or capital gains tax triggers, including capital gains events. This step links the record to future filing obligations.
Submitting the declaration and what to save for your records
Before you submit, check all fields and save screenshots, PDFs and the reference shown. If the record becomes taxable you will get a UTR for Self Assessment and possible SA900 filing.
“Check names, NI numbers and dates twice before you click submit.”
After registration: claiming the trust and using your URN or UTR
Once the register shows the arrangement as recorded, claiming it ties the lead trustee to future correspondence and control.
Who can claim the record
Only the lead trustee named during sign‑up can claim on the TRS. This person becomes the main contact, even though all trustees share legal duties.
What the HMRC letter looks like and why the number matters
You will receive a postal letter with either a 15‑character URN (for non‑taxable records) or a 10‑digit UTR for taxable affairs. Treat that number as sensitive. Store a scanned copy in a protected folder and share it securely with your solicitor if needed.
Accessing and using “Manage Your Trust’s Details”
Claiming requires the lead trustee’s contact details plus the URN/UTR. Log in with your Government Gateway to reach “Manage Your Trust’s Details” and check what appears on the register.
- Check names and dates match the original entry before claiming.
- Keep the number handy for future letters and online updates.
- If you act on behalf of others, use the lead trustee’s account — TRS ties access to that identity.
| Action | What you need | Outcome |
|---|---|---|
| Claim the record | Lead trustee contact + URN/UTR | Full access to manage details |
| View register | Government Gateway login | See current details and download proof |
| Share safely | Scanned copy in protected folder | Quick proof for banks or advisers |
For step‑by‑step guidance on claiming the record and using the service, see our short guide on registering as a trustee.
Keeping the trust register up to date and meeting ongoing duties
A tidy, current record helps trustees avoid penalties and reduces friction in estate matters. Keeping details current is part of everyday duty. Small changes can matter.
What counts as a change you must report
Report changes to trustees, beneficiaries, addresses and any updates to assets or tax position. Also tell the register about new property, money, company shares or business interests.
The 90-day update rule and risks if you miss it
Update within 90 days whenever details change. Missing this deadline can lead to queries from banks and advisers and increase penalty risk.
If you delay, you may face fines and extra hassle when proving information later.
Annual declaration and the 31 January deadline
For taxable arrangements, file the yearly declaration by 31 January. You must do this even when nothing has changed.
When SA900 may also be needed
If the arrangement is liable to income or capital gains tax you may also need to file the Self Assessment Trust and Estate Tax Return (SA900). TRS updates do not replace tax returns.
Penalties and a simple maintenance routine
HMRC can charge penalties up to £5,000 for failures to register or keep information up to date. That makes regular checks worth the small effort.
- Quarterly check on details and assets.
- Set a January reminder for the annual declaration.
- Keep scanned evidence and values in one secure folder.
| Duty | When | Action |
|---|---|---|
| Report changes | Within 90 days | Update details on TRS |
| Annual declaration | By 31 January | Confirm details even if unchanged |
| Tax return (SA900) | When liable to income or gains tax | File Self Assessment alongside TRS |
“Keep details current; routine checks avoid costly surprises and speed up dealings with banks and advisers.”
Special situations: agents, proof of registration and risk of harm reporting
When trustees are busy or the paperwork is complex, an experienced solicitor or tax agent can step in and handle the online steps for you.
What agent authorisation covers (and what it doesn’t)
Agents may register records on your behalf using the TRS service and can download evidence for banks or advisers.
Important: that action does not automatically let an agent file tax returns or act in Self Assessment. Separate authorisation is usually required to speak to HMRC about tax affairs.
Downloading proof for new business relationships
You can get a PDF called “Get evidence of the trust’s registration” from the online service. Banks, mortgage lenders and investment providers often ask for this when a relationship starts.
Keep a current copy in a secure folder. It often removes practical hold‑ups during house sales, remortgages or transfers.
Beneficial owners at risk: how to alert HMRC quickly
If someone named on the record faces a disproportionate risk of harm, you can email trs.riskofharm@hmrc.gov.uk. Use the subject line: “Beneficial owners at risk of harm”.
- Include URN/UTR and the record name.
- Give the lead trustee’s name and which beneficial owners are at risk.
- Describe the risk (fraud, kidnapping, blackmail, extortion, harassment, violence, intimidation), reasons and how long it may last.
HMRC reviews requests and replies in writing. If they accept the case, assurances last for 12 months. Renew the measure between months 11 and 12 if the danger continues.
“If safety is at stake, act promptly and include full details in your email so HMRC can respond swiftly.”
| Situation | Agent role | Practical action |
|---|---|---|
| Complex paperwork | Submit details on your behalf | Ask agent to keep you copied and get written consent |
| New bank or lender | Download proof PDF | Share secure PDF to avoid delays |
| Beneficial owner at risk | Inform HMRC via email | Send full facts, URN/UTR and renew if needed |
For step‑by‑step help when using an agent, see our practical guide to register your client’s record.
Closing a trust on the TRS when assets have been distributed
Closing the record on TRS marks the end of administration once nothing remains under trusteeship. This step is appropriate when all assets have been transferred and the trustees no longer hold anything for beneficiaries.
Choosing the correct closure date and ensuring details are up to date
Log in, answer the security checks and pick “Close the Trust…” in the service. Enter the closure date as the day every asset was appointed or actually transferred out.
Examples: the date a property transfer completed, or the date the final bank funds left the account. Make sure all names, addresses and asset entries are current before you close.
Completing the declaration and saving evidence of deregistration
Complete the final declaration, then print or save the confirmation. That PDF is proof the record was closed and should sit in your secure file with the final accounts.
Closing yourself vs authorising a solicitor to act on your behalf
Trustees can close the record themselves using their Gateway login. Alternatively, you can authorise a solicitor via the agent link to act on your behalf.
When to pick a solicitor: if transfers are complex, or you prefer the professional to handle the final paperwork and keep your family file tidy.
- Confirm no remaining assets.
- Check beneficiaries have been paid.
- Ensure TRS details match your final paperwork.
- Save the final declaration and retain records for the trust’s final period.
“Close the record only once you can show all assets were dealt with and you have saved the closing evidence.”
| Action | What to enter | Why it matters |
|---|---|---|
| Choose closure date | Date last asset left | Matches deeds and bank records |
| Update details | Names, addresses, assets | Avoids queries later |
| Save evidence | Final declaration PDF | Proof for solicitors or banks |
Conclusion
In short, early checks and simple steps protect family assets and avoid late penalties.
Check whether your arrangement must be on the TRS and, where an exemption may apply, keep notes to show why.
Practical flow: gather what you need provide, set up your Government Gateway, use the trust registration service path, then claim and maintain the record.
Remember the difference: non‑taxable records usually give a URN; taxable ones give a UTR and bring ongoing duties such as the 31 January declaration.
Keep secure files, share key details with co‑trustees, and set diary reminders for 90‑day updates. Seek expert help for complex beneficiaries, overseas elements or unclear tax triggers.
Work step‑by‑step. It saves stress and keeps your family’s plans on track.