We know how stressful admin can feel when a family arrangement looks informal but still needs formal steps. In simple terms, the hmrc trust register deadline tells you when to give official details so you avoid fines.
We’ll explain what the deadline means in everyday terms and why it matters for homeowners and families holding property, savings or funds for children.
We’ll also highlight the common gotchas, such as rules linked to anti-money laundering rather than tax, and show how to spot the right date for your situation.
Finally, we set out the real consequences of missing deadlines and give practical guidance on steps to take today to reduce risk, keep records tidy and act early to avoid penalties.
Key Takeaways
- Act early: know the correct date for your arrangement to avoid a fine.
- Informal family plans can still meet the legal tests for registration.
- Some obligations arise from anti-money laundering rules, not just tax.
- Prompt correction often reduces the chance of higher penalties.
- Keep simple records and seek clear guidance if unsure.
Understanding the Trust Registration Service and why it matters
The trust registration service is the online system where trustees record key details about who controls and benefits from assets.
We use the service for two linked reasons. First, it helps meet anti‑money‑laundering checks. Second, it shows when a trustee must have a Unique Taxpayer Reference (UTR) to file a trust Self Assessment.
Who it’s for:
- Trustees managing family assets.
- Personal representatives in some estate situations.
- Agents acting on behalf of trustees.
The system exists beyond just tax. Even if a trust has no tax to pay, trustees may still need to use the registration service to comply with AML rules.
Having a UTR often triggers the need to enter details, so needing a UTR can override some exemptions. Registering the trust is not the same as filing tax returns. One records the arrangement; the other reports taxable income or gains.
Expect ongoing duties: trustees must keep records current and update the service when people or assets change. It is not a one‑off task.
Does your trust need to register with HMRC?
Start by asking a few practical questions to spot if your arrangement must be recorded. We keep this short and clear so you can check quickly.
Most UK express trusts
Most UK express trusts must be recorded even if they make no tax charge. If a settlor deliberately created the arrangement and appointed trustees, that label matters for whether you need register trust details.
Non-UK express setups with UK links
Non-UK arrangements are caught when they buy UK land or when a UK-resident trustee starts a business relationship in the UK. In practice, a family buying a buy-to-let in England will usually need to register.
When tax exposure forces action
Registration is also triggered when the arrangement becomes liable for UK income or capital gains. Typical tax events include:
- Income from bank interest or rents;
- Gains on selling shares or property;
- Inheritance tax, SDLT, LBTT or LTT and similar property taxes.
Note: claiming reliefs via Self Assessment does not always remove the need to register. If you are unsure, act early and seek specialist help.
Excluded express trusts and common exemptions to check first
Not every arrangement needs recording — here are the common exemptions to check first.
Schedule 3A is the list of “excluded express trusts” that normally do not need registration. In plain terms, these are setups the system treats as outside routine reporting.
“An exclusion can change if the arrangement becomes liable for UK tax — tax liability defeats the exclusion.”
Common examples to look for
- Pension scheme and some statutory arrangements.
- Life policy trusts that only pay out on death, illness or disability.
- Charitable arrangements and child bank account trusts.
Will trusts and estates usually slip the net if they close within two years after death. If they remain open beyond that, you must check for any tax event.
Pilot trusts set up before 6 October 2020 and holding under £100 are treated differently from those created after october 2020. Newer pilot arrangements often need information to be supplied by september 2022 or under later rules.
Some co-ownership cases (tenants in common) and professional client money arrangements are also excluded. Always confirm whether the arrangement is one of the listed non-taxable trusts or whether a later tax charge makes registration necessary.
hmrc trust register deadline: the key dates and how to find yours
Start by finding the creation date and any first tax event — that pins down the date you must meet.
Here is a simple route map to find your register date.
Older non‑taxable arrangements
Non‑taxable trusts created on or before October 6, 2020 needed to be recorded by 1 September 2022. This historic cut‑off affected many family setups.
Newer non‑taxable or taxable arrangements
For non‑taxable trusts created after October 6, 2020, the rule is to register within 90 days of creation or of becoming liable for tax. The same within‑90‑days rule applies to taxable trusts created on or after April 6, 2021.
Pre‑April 2021 Income or gains events
If a pre‑April 6, 2021 trust becomes newly liable for income or capital gains, the register date is 5 October following the tax year.
Previously liable and other taxes
Pre‑April 2021 trusts that were already liable must use 31 January following the tax year. Other taxes, including inheritance tax and property triggers, also use 31 January.
“If more than one date could apply, meet the earlier date — it is the safe option.”
Example: a trust that starts receiving bank interest mid‑year must be recorded within 90 days of that first income. If a property purchase causes tax exposure, the 31 January timing may apply.
For agent guidance and practical steps, see our agent advice guide.
How to register a trust online using HMRC’s service
We walk you through the online process so you know each step before you sit at the keyboard.
Start by signing in with Government Gateway credentials. Use the correct role: lead trustee details need a trustee sign‑in, while advisers must use an agent account.
Government Gateway access and account setup
Create a Government Gateway user if you do not already have one. If you act for others, set up an Agent Services Account first.
Registering as an agent
Agents must request permissions to view or update records. Registering the arrangement on the service does not automatically give an agent authority to act.
After submission — what to expect
HMRC usually issues a UTR for taxable cases, or a unique reference for non‑taxable cases, within 15 working days.
- Save the submission confirmation PDF.
- Download any evidence or reference numbers shown on screen.
- Keep a copy of the Government Gateway logins and confirmation emails.
| Step | Who signs in | Expected outcome |
|---|---|---|
| Create account | Trustee or agent | Government Gateway user ID |
| Complete online form | Lead trustee or authorised agent | Submission confirmation and reference number |
| Wait for processing | Trustee or agent | UTR or unique reference (usually within 15 working days) |
Need help? For step‑by‑step official guidance see register a trust as a trustee.
What information you’ll need before you start the registration
Gathering the right information first saves time and avoids repeated edits. Below we list the key facts and documents you should have to hand before you begin the online service.
Core trust details
- Name of the arrangement and its creation date.
- Whether it is an express trust and any founding paperwork (the trust deed).
- Any non-UK business relationship that affects the arrangement.
UK property and land details
If the arrangement bought UK property, note full addresses, purchase dates and any tax events. HMRC asks specifically about land purchases when you complete the online form.
Appointing the lead trustee
The lead trustee is the main contact for the service. HMRC will ask for the lead trustee’s name, date of birth, national insurance number (or passport details for non-UK individuals), address, phone, nationality and residence. For organisations include the company name and UTR.
People linked to the arrangement
- Settlors: full name, date of birth (and date of death if relevant), last residence and nationality. For a living settlor, answer the mental capacity question.
- Other trustees, protectors and beneficiaries: name, date of birth, nationality/residence and one form of ID (NI number, passport or UK address).
- Where a beneficiary class is used (for example “future grandchildren”) note the class wording. If a class later becomes specific, update the record.
When there are more than 25 beneficiaries
Record all known beneficiaries. If a beneficiary type exceeds 25 entries, keep the extra records yourself and list the first 25 on the service. This is a common and accepted approach.
Extra details for taxable arrangements
Taxable cases need the trust type, how it was set up, any existing UTR, Schedule 3A status and sensible asset valuations (shares, property, business interests, cash and other assets) at the time of registration.
“If you gather these details before you start, the online form is straightforward and much quicker to complete.”
| Category | What to gather | Where to find it |
|---|---|---|
| Core details | Name, creation date, express status | Trust deed; settlor paperwork |
| Lead trustee | Name, DOB, NI/passport, address, phone | Passport, NI record, trustee contact list |
| Property & land | Addresses, purchase dates, tax events | Title deeds, solicitor invoices, SDLT returns |
| Beneficiaries | Names, DOBs, nationality/residence or class wording | Beneficiary list, wills, family records |
For official procedural guidance on using the online service see our practical guide on registering a trust in Britain and the government pages on how to manage your trusts on the registration.
Keeping the trust registered and up to date after the deadline
Maintaining an accurate record is ongoing work. Life changes — people move, inheritances arrive, and roles shift. We recommend treating updates as routine maintenance rather than a one‑off chore.
How to report changes to trustees, settlors or beneficiaries
Report changes via the online service once authorised. Common changes include new trustees, a settlor’s death, or beneficiaries becoming known. Keep updates prompt and factual.
- Trustees: add or remove names, update contact details.
- Settlors: note deaths or changes to nationality or residence.
- Beneficiaries: record named beneficiaries or amend class descriptions.
Agents can only make updates after they hold the correct authorisation. If an adviser acts, ensure the required permission is in place before asking them to amend the record.
Proof of registration for new business relationships and “relevant persons”
When you open an investment account or deal with a solicitor, the other side may ask for proof of registration. A relevant person is anyone who needs to verify the arrangement — banks, accountants or estate professionals.
“Keep the evidence PDF saved after every change so you can show up‑to‑date proof at short notice.”
Use the service to download the proof of registration PDF from ‘Get evidence of the trust’s registration’. Save a dated copy each time you update details.
| Action | Who does it | Why it matters |
|---|---|---|
| Add/remove trustees | Lead trustee or authorised agent | Keeps decision‑makers accurate for legal and AML checks |
| Update settlor status | Lead trustee | Reflects lifespan or residency changes that affect obligations |
| Provide proof of registration | Trustee or agent | Needed for new business relationships and to satisfy a relevant person |
Simple habit: after any change, download the evidence PDF, save it with the date, and store a copy with your trust paperwork. This small step reduces friction when a bank or adviser asks for current details.
For step‑by‑step help on setting up or updating details, see our guide on registering.
Penalties for missing deadlines and how to reduce the risk of fines
Late or incorrect filings usually come from poor organisation, not deliberate refusal to comply. That makes most problems avoidable with a simple routine.
HMRC’s penalty position for failures to register or keep details updated
There is a clear penalty risk. Trustees may face a £5,000 charge for failing to register or for not keeping registration details up to date. Reminder notices may arrive, but they do not remove liability.
Common mistakes that cause late registration or incorrect details
- Assuming “no tax” means no registration — that is often wrong.
- Missing the 90‑day window after creation or first taxable event.
- Using old contact information for trustees or beneficiaries.
- Failing to close records for arrangements that have ended.
Practical compliance checklist for trustees and agents
| Action | Who | Why |
|---|---|---|
| Record creation & first income date | Lead trustee | Pins registration timing |
| Save evidence PDF after every change | Trustees / agent | Proof when asked |
| Annual review and diarise updates | Trustees | Prevents drift and fines |
“Do it once, do it right: register promptly, save the evidence and diarise regular reviews.”
Example: a family trust buying UK property must check SDLT timings and update information quickly to avoid penalties.
Future changes to watch: AEOI registration deadline by 31 December 2025
New AEOI rules from July 2025 mean some arrangements must complete a simple registration even if they have nothing to report.
Which entities are in scope? The rule captures entities classed as a Reporting Financial Institution under CRS/FATCA and those treated as Trustee‑Documented Trusts.
Practical meaning of a Reporting Financial Institution
In practice this can include a family structure that holds an investment portfolio managed by professional services. If a bank, platform or manager treats the arrangement as a financial person, the arrangement may be in scope.
Key dates and penalties
Existing affected entities must complete registration by 31 December 2025.
New affected entities must register by 31 January following the calendar year they first qualify.
“Penalties start at £1,000 with possible ongoing fines of £300 per day unless a reasonable excuse applies.”
Operational notes for agents and teams
Agents can file batches of up to 250 registrations in one submission. Note you cannot make another filing for 24 hours after a batch.
| Item | Who is affected | Deadline / notes | Penalty exposure |
|---|---|---|---|
| Existing reporting entities | Reporting Financial Institutions & Trustee‑Documented Trusts | 31 Dec 2025 | £1,000 + £300/day |
| Newly qualifying entities | Arrangements that become reporting during year | 31 Jan after the year they first qualify | Same as above |
| Agent filings | Agent or authorised person | Up to 250 per filing; 24‑hour gap between submissions | Late filings risk daily fines |
If your arrangement holds financial assets or uses professional managers, check AEOI classification now rather than late in 2025.
Conclusion
In short, getting the timing right comes down to the type of arrangement, when it began and whether it faces tax or anti‑money‑laundering rules.
Many ordinary family trusts do need listing, and an exclusion is not automatic. Check the rules rather than assume you are exempt.
Accuracy matters. Keep details current and save proof after every change. This avoids fines and smooths new business checks.
Treat registration as part of protecting the family plan — a small admin step that prevents bigger problems later.
Next steps: gather the deed and key parties’ details, confirm any exclusion, diarise the earliest date and, if assets are professionally managed, check AEOI rules well before 31 December 2025. For practical help see our guide to protect your family’s future.