We explain the HMRC trust register in plain English. It is the official route to record who benefits from a trust and, when needed, to obtain a Unique Taxpayer Reference via the TRS.
Our aim is to make the process feel manageable. We set out what matters for British homeowners and families, and why banks, insurers and providers may ask for proof that a trust is on the register before they act.
Even if a trust pays no tax, registration may still be required. The rules changed after October 2020 and deadlines now carry real consequences, including penalties and anti-money laundering concerns.
We introduce the key players — settlors, trustees and beneficiaries — and explain the practical information you must supply. We also outline what happens after registration and common mistakes that cause delay.
Key Takeaways
- The TRS is the single route for trust registration and UTRs where relevant.
- Registration can be required even when no tax is due.
- Banks and providers often demand proof of listing on the trust register.
- Deadlines matter — late filings can lead to penalties.
- We break the process into clear steps to avoid common delays.
Understanding the Trust Registration Service and why it exists
We explain what the trust registration service does and who it protects. The system began in 2017 for taxable arrangements and expanded after the Fourth and Fifth Money Laundering Directives. From October 2020, most UK resident non-taxable arrangements in existence on or after 6 October 2020 must appear on the TRS.
The registration service is the government’s central record of beneficial ownership. It holds information on the settlor, trustees, beneficiaries, key dates and sometimes assets or controllers. A registered trs entry may show a UTR for taxable cases or a URN for non-taxable ones.
Organisations such as banks and investment providers often ask for TRS evidence and your URN. They must check details against HMRC records and report material mismatches. That is why accuracy matters: a simple change of trustees or a withdrawal can be paused until the firm sees the correct details.
- Central purpose: prevent hiding money or assets.
- What is held: names, dates, beneficiaries and sometimes assets.
- Practical effect: providers may delay transactions until they see TRS proof.
Who must register on the hmrc trust register
We break the scope down so you can quickly spot if you need to act. There are three broad groups to check: arrangements with a UK tax liability, most UK-based arrangements even if non-taxable, and overseas arrangements with a UK link.
UK and non-UK arrangements with a UK tax liability
If the arrangement faces UK income tax, capital gains tax, inheritance tax, SDLT (or Scottish/Welsh equivalents) or stamp duties, it must appear on the TRS. That applies whether the arrangement is UK resident or not.
Non-taxable UK arrangements that still need listing
Many people assume no tax means no paperwork. That is not always the case. Most UK arrangements created before or after the 2020 change still need details on the central record, even when no tax is payable.
Overseas arrangements brought into scope
An overseas arrangement must be shown if it has at least one UK resident trustee, if it forms a business relationship with a UK obligated entity (for example a bank or investment provider), or if it acquires UK property.
Generally, arrangements created from 1 September 2022 must be listed within 90 days. Most required listings and significant updates must be notified within 90 days of the event.
- Typical events needing updates: appointment or resignation of a trustee, new beneficiaries, or a change of contact details.
- If you are unsure whether you need register, check early to avoid penalties and delays with banks and providers.
For step‑by‑step help on the process and examples, see our guide on registering a trust in Britain.
Trusts that are excluded from registration and common grey areas
There are clear exclusions and a few grey areas that commonly confuse families. We summarise the typical categories and show where you should check further.
Common exclusions include UK-registered pension schemes, regulated charitable arrangements and protections held solely as life cover. Court-imposed settlements and implied arrangements from joint ownership are also usually outside scope.
Special family examples: bereaved minor arrangements, vulnerable beneficiary funds, Child Trust Funds and Junior ISAs are often excluded. Will-related settlements that are wound up within two years of death may also be outside the list if assets and funds are fully distributed.
| Exclusion | Typical example | When action may still be needed |
|---|---|---|
| Pensions & charities | Workplace pension; registered charity fund | Only if there is a UK tax link |
| Children’s accounts | Junior ISA; small bank account | Investment portfolios for a child usually need registration |
| Small asset rule | Arrangements pre-6 October 2020 under £100 | Becomes registerable if more assets are added |
One tricky area is bare trusts. A parent holding a child’s bank account may be excluded, but a portfolio held for a minor usually requires you to register. If there is any UK tax liability, exclusions do not apply and a failure to act can bring penalties. For agent guidance see our agent advice page.
What you need before you register a trust with HMRC
Getting the right information together first makes the online process far quicker and reduces costly errors. Gather core documents and check names and dates against the deed before you start.
Core details HMRC expects
We advise collecting:
- the arrangement’s name and key date(s);
- full details for each trustee and the settlor, including contact info;
- beneficiary identities or their description and any controlling person (often called a protector).
Lead trustee role and joint liability
The lead trustee is the main point of contact for the registration service. They keep logins and references safe and complete filings.
All trustees remain jointly liable for accuracy and any penalties. One person doing the admin does not remove responsibility from others.
When to appoint an agent
Appoint an agent when there are many beneficiaries, overseas links, or frequent changes. An agent can reduce mistakes and speed up the trust registration process.
| Task | Who provides it | Why it matters |
|---|---|---|
| Identity details | Settlor & trustees | Matches deed and avoids delays |
| Beneficiary list | Trustees | Shows who benefits and when |
| Controller details | Trustees/settlor | Needed if a person can influence decisions |
How to register, claim and manage your trust on the TRS
We guide you through the online steps so the paperwork feels straightforward and stays secure.
Setting up Government Gateway access as an organisation
Create a Government Gateway organisation account because you act on behalf of the arrangement. Keep your Gateway ID, password and security method safe.
Only the lead trustee can claim the record. If you use an agent on behalf of trustees, give clear written authority.
Submitting registration and obtaining a UTR or URN
Submit the details on the trust registration service (trs). HMRC posts a letter with the URN for non-taxable listings or a UTR for taxable cases.
Claiming, safekeeping and avoiding lockouts
Claiming links the registered trs record to the lead trustee’s Government Gateway account. Match personal details exactly to HMRC’s records.
Three incorrect attempts can trigger a 30‑minute lockout. Keep the URN/UTR safe and share a copy with your solicitor to avoid delays in future administration.
- Tip: store your URN/UTR with other estate documents.
- Tip: present evidence of a trust registered on TRS when dealing with banks and providers to reduce hold-ups.
For official guidance on the process see manage your trusts registration service.
How to stay compliant after registration
A few simple habits will keep you compliant and avoid unnecessary penalties. Make a yearly plan and diary key dates so the burden does not fall on a single person at short notice.
Reporting changes within 90 days
Any change — new trustees, resignations, beneficiary additions or amended details — must be updated online within 90 days of the event. The 90-day rule also applies when a new arrangement is created.
Annual review and declaration for taxable arrangements
Taxable arrangements need an annual review. Even if nothing changed, make the formal annual declaration, usually by 31 January, so you avoid a penalty for failure to confirm details.
How TRS updates link to the SA900 tax return
Keep the central record and the trust and estate tax return consistent. If liable to Income Tax or Capital Gains Tax, trustees must file the SA900 and confirm the online entry is up to date when completing the form.
“Deliberate failure to keep details updated can incur penalties up to £5,000.”
| Action | Deadline | Who acts |
|---|---|---|
| New trustee appointment | Within 90 days | Lead trustee |
| Beneficiary change | Within 90 days | Trustees |
| Annual declaration (taxable) | By 31 January | Trustees / agent |
Practical tip: keep one folder with your URN/UTR, deed and key dates. That saves time and reduces the risk of failure when dates arise.
Conclusion
A few simple steps now can save your family time and trouble later.
Many UK and overseas trusts are in scope, so it pays to check whether you need registration rather than assume older rules apply.
Identify if you must register, gather deeds and identities, choose a lead trustee, then complete the online process so you can prove status to banks and providers.
Keep your URN/UTR safe. That reference speeds dealings with the government and avoids holds on assets when you most need access.
Non-compliance can trigger an initial penalty of £100 and, if deliberate, wider anti‑money‑laundering consequences. Small annual checks prevent bigger problems.
If you are unsure whether your trusts created are in scope, speak to a solicitor or an agent experienced in registering a trust so you do it correctly first time.