HMRC Trust Updates: Key Changes for 2025

We set out the key 2025 changes in plain English so family trustees and their advisers can act without delay.

New rules mean your trust registration details must be accurate and updated promptly. If you do not make changes within 90 days of a reportable event, enforcement is possible and fines can be severe — up to £5,000 per offence.

There is also an international element this year. Certain arrangements classified as Financial Institutions (FI) or Trustee-Documented Trusts (TDT) must complete Automatic Exchange of Information (AEOI) registration by 31 December 2025. This applies even where there are no reportable persons — a significant widening of the previous rules.

We will explain the two practical themes: keeping the Trust Registration Service (TRS) entry correct and having proof of registration ready for banks and advisers who are now required to check it.

By the end you will know whether these changes affect your trust, what checks to run, and the next steps to protect your family’s affairs and meet your obligations to HMRC.

Key Takeaways

• Update trust registration within 90 days of any reportable change to avoid fines of up to £5,000 per offence.
• Certain trusts classified as FI or TDT must complete AEOI registration by 31 December 2025 — even without reportable persons.
• Trustees should review their TRS records, log in via Government Gateway, and download a fresh digitally signed proof of registration.
• Since September 2022, banks, solicitors, and other obliged entities routinely request proof of registration — delays in providing this can freeze transactions.
• Act now: simple checks reduce enforcement risk and keep your estate planning on track.

What these 2025 updates mean for UK trustees and estate planning

Simple life changes now often mean you need to amend your trust record promptly. We see this regularly in everyday estate planning: a beneficiary marries or divorces, a new trustee is appointed, a settlor changes address, or a trustee passes away.

Keeping the Trust Registration Service up to date is now practical compliance work, not just form-filling. It demonstrates you are meeting your legal duties as a trustee and prevents delays when banks, solicitors, or financial advisers ask for proof of registration — which they are now required to do.

Who is most affected

All UK express trusts — including bare trusts — are required to register on the TRS following the implementation of the 5th Money Laundering Directive. Trustees who manage family arrangements such as discretionary trusts, interest in possession trusts, and property protection trusts must check the register more often than many realise.

Solicitors, accountants, and financial advisers will increasingly ask for accurate registration evidence before they proceed with any work. That can slow down estate administration, property transactions, or investment changes if you cannot produce proof of registration promptly.

• Common triggers: new trustees appointed, trustees removed, changed beneficiary details, updated contact details, death of a settlor or trustee.
• Why it matters: proof of registration speeds up account openings, investment moves, and property transactions.
• Practical tip: treat your trust file like a household document you review at least once a year — and immediately after any change.

For practical guidance on how recent rule changes affect estate plans more broadly, see our note on how the new inheritance tax rules affect your family’s future. We suggest trustees review records regularly and keep proof of registration ready to share at short notice.

HMRC trust updates: the headline compliance changes to act on in 2025

Three compliance headlines for 2025 will determine whether your records pass routine checks from HMRC and the obliged entities you deal with.

TRS details must be reviewed and updated within 90 days of any change

Trustees must review the Trust Registration Service entry whenever facts change — and not only when HMRC asks.

Any change in trustees, beneficiaries, settlor details, or lead trustee contact information needs an update within 90 days of the date the change took effect. Reviewing what is already on the register is just as important as making updates, particularly where earlier entries may have contained errors.

Proof of registration checks and discrepancy reporting continues to tighten

Since 1 September 2022, obliged entities — banks, building societies, solicitors, accountants, and financial advisers — must ask for proof of TRS registration or evidence of an exemption before proceeding with business. They also compare what you provide against the information held on the trust register.

If an obliged entity finds material discrepancies between your proof document and the information they hold, they may be required to report them to HMRC. That can slow or entirely stop account openings, investment transfers, and property transactions.

“Keeping proof ready avoids delays and shows you are taking your trustee duties seriously.”

New AEOI registration requirement for certain trusts under CRS/FATCA rules

For 2025, amendments to the International Tax Compliance Regulations mean that some arrangements classified as Financial Institutions (FI) or Trustee-Documented Trusts (TDT) must register for AEOI separately. This is a different registration from the Trust Registration Service and carries its own deadlines and penalties.

We recommend you identify whether your trust needs TRS actions, AEOI actions, or both. Build a simple compliance rhythm: check the register, update where necessary, download a fresh proof document, and store it securely alongside your trust deed and other trust administration records.

Trust Registration Service basics you should re-check before making any updates

Start by confirming the basic facts held on the register against your original trust deed and any subsequent deeds of appointment, removal, or variation. Small gaps — a middle name missing, an outdated address — can be flagged as material discrepancies. That slows banks and advisers and can trigger formal reporting to HMRC.

We suggest a short, practical pre-flight check before you log in. Gather the trust deed, any deeds of appointment or removal, identification documents for all persons named on the register, and current contact details. This makes the update process quicker and more reliable.

What the register holds and why it matters

The Trust Registration Service records core information about the trust arrangement and its beneficial owners. That includes names, dates of birth, addresses, nationality, and the role each person plays — whether they are the settlor, a trustee, or a beneficiary. It is important to note that the TRS register is not publicly accessible (unlike Companies House), so your family’s details remain private. However, obliged entities can verify information against it when conducting due diligence.

Who counts as a beneficial owner for TRS purposes

In plain terms, beneficial owners include the settlor (the person who created the trust arrangement), all trustees, named beneficiaries, and any person who exercises control over the trust arrangement. For family discretionary trusts, this often means the settlor, their spouse, children, grandchildren, or other persons named in the trust deed. Where beneficiaries are described as a class (for example, “all my grandchildren born or yet to be born”), the class description is registered rather than individual names. This is one of the privacy advantages of a discretionary trust — no single beneficiary has an automatic right to income or capital, and the class description keeps things flexible.

“Missing a nationality or having an incorrect address can be treated as a material discrepancy — and that can freeze a transaction.”

• Check that all names and dates of birth match current identification documents.
• Confirm nationality and current residential address for each beneficial owner.
• Have deeds showing trustee appointments, removals, or beneficiary changes ready before you log in.

For trustees acting as agents on behalf of other trusts, see our guidance on registering as an agent before you log in.

How to log in and access your trust record using Government Gateway

We recommend you gather the Government Gateway user ID and password before you start.
You will usually need a two-step verification access code as the final step before gaining entry.

What to expect when you sign in:

What you need to sign in: Government Gateway user ID, password and access code

Have the designated Government Gateway user ID and password ready.
When prompted, enter the two-step verification access code sent to your chosen device or email address.

Set up at least two ways to receive access codes — for example, a mobile phone number and a backup email address.
Having a secondary method reduces the risk of being locked out, particularly if a trustee changes their phone or loses access to an email account.

Lead trustee identity details you may be asked to confirm

The sign-in process can ask for the lead trustee’s full name, date of birth, and National Insurance number or passport details.
Keep these documents handy to avoid delays. If the lead trustee has changed since the trust was first registered, this step may require additional verification.

Maintaining access when circumstances change (new phone, new email, new trustee)

Plan for change. Add a secondary contact method and update the Government Gateway user details promptly if a lead trustee steps down or a new trustee is appointed.

If you cannot recover access quickly, seek professional support from a solicitor or trust administration specialist.
Act early so you can still meet the 90‑day update window. Losing access to the Government Gateway account does not excuse a late update — HMRC expects trustees to maintain access as part of their ongoing duties.

How to update the Trust Register within the 90-day deadline

When something in the trust arrangement changes, you should log into the TRS and make the correction within 90 days — that is roughly three months. We recommend a simple checklist approach to keep you on track, because once the deadline passes, HMRC can impose penalties without warning.

Common changes that trigger an update

Most triggers are straightforward: appointment or removal of trustees (by deed), addition of new beneficiaries, death of a settlor or trustee, change of lead trustee, and updated contact details. Always record the date the change took effect — this is the date from which your 90 days runs.

Updating trustee details and lead trustee contact information

Log in with the Government Gateway account and carefully amend names, dates of birth, and contact details. Banks and financial advisers check here first when carrying out due diligence, so accuracy is essential. If a trustee has been removed or has resigned, ensure they are marked as no longer active on the register. Remember, a trust arrangement must have a minimum of two trustees at all times — if a resignation or death brings you below that number, appointing a replacement trustee should be your first step, followed promptly by a TRS update.

Correcting beneficial owner information

Incomplete beneficiary or settlor details are one of the most common causes of discrepancy flags from obliged entities. We suggest cross-checking names, dates of birth, and addresses against current identification documents before you save any edits.

Changes to assets and financial arrangements

Record material asset changes where they alter the nature or value of the trust arrangement — for example, where property is transferred into or out of the trust, or a significant new investment is made. Bear in mind that transferring property into a trust may involve a TR1 form (where there is no mortgage) or a Declaration of Trust (where a mortgage is in place and the lender’s consent cannot be obtained). If the trust arrangement holds property, ensure the Land Registry details also reflect the current trustees. If in doubt about whether a change is reportable, it is better to update the register and make a note of why.

What “within 90 days of the date of change” looks like in practice

For changes made by deed — such as appointing a new trustee — the effective date is the date on the deed. For events like a death or marriage, the effective date is the date of the event itself. Diarise the 90-day deadline as soon as the change occurs and keep a short audit trail of what you changed, when, and why.

“Note the date, update the register, and save the proof. It takes minutes now — and saves months of headaches later.”

For step‑by‑step help on the registration process itself, see our guide on registering a trust in Britain. Keep a short log of all changes and download a fresh proof of registration after each edit.

Understanding HMRC penalties and personal liability for trustees

We explain what can happen when register details are not kept accurate. Even a brief lapse can lead to enforcement action and penalties. Trustees need clear, practical steps to reduce risk — because the consequences fall on them personally, not on the trust arrangement.

TRS enforcement action and fines of up to £5,000 per offence

Fines can be substantial. For failures to register or keep the register accurate, HMRC can impose penalties of up to £5,000 per offence. Each separate failure — a missed update, an unregistered trust, an incorrect entry left uncorrected — can constitute a separate offence. Repeated or unresolved discrepancies increase the likelihood of active enforcement.

Why trustees can be personally liable for failures (not the trust arrangement)

A trust is not a legal entity in English law — it is a legal arrangement. It has no separate legal personality, cannot be fined, and cannot be sued in its own name. The trustees are the legal owners of the trust property and carry the legal duties to manage the arrangement properly. That means personal liability for registration failures falls on the individual trustees, not on the trust arrangement itself.

This is a fundamental point that many family trustees do not fully appreciate. England invented trust law over 800 years ago, and this principle has remained constant throughout: the trustees hold the legal title and bear the legal responsibilities. If you are named as a trustee, you are personally responsible for ensuring the TRS record is accurate. This is no different in principle from the other duties trustees owe — the duty to act in the best interests of beneficiaries, to keep proper accounts, and to act within the terms of the trust deed.

“Small admin gaps can become big legal and financial problems if left unaddressed. Plan, don’t panic — a few minutes of regular review prevents months of difficulty.”

Practical risk reduction

• Review records at set intervals (at least annually) and immediately after any change.
• Update the register promptly and download a fresh digitally signed proof of registration.
• Keep a short audit note of what changed, when, and who made the update.
• Seek professional help from a solicitor or trust specialist if changes are complex or you manage multiple trust arrangements.

Proof of registration: how to download, store and share the digitally signed document

A digitally signed proof of registration is now one of the most important documents trustees hold for managing family trust affairs day to day.

What it is: a PDF generated by the Trust Registration Service showing the current details held on the register and bearing a digital signature from HMRC. You can download or print it directly from the service after logging in via Government Gateway.

When you will need it: opening bank accounts in the trustees’ names, making investments, dealing with property transactions, and whenever an obliged entity — a bank, building society, solicitor, or financial adviser — asks for verification. Since September 2022, providers are required to request this when forming a new business relationship and during periodic reviews of existing ones. One of the key practical benefits of having a well-maintained trust arrangement is that trust assets bypass probate delays entirely — trustees can act immediately on the settlor’s death without waiting for a Grant of Probate. But only if the registration records are up to date and ready to share.

Keep the latest PDF and refresh it after every edit to the register. A current copy avoids questions about mismatched records and speeds up routine dealings with banks and advisers. For guidance on managing the online account itself, see the official guidance on managing the Trust Registration Service.

“A current, digitally signed PDF prevents delays and demonstrates you are taking your trustee duties seriously.”

Working with “obliged entities” since September 2022: what they will ask for

Organisations that provide banking, financial, or professional services now routinely request TRS registration evidence before they will proceed with any transaction. This requirement has been in force since September 2022 under UK anti-money laundering regulations and affects many everyday relationships that trustees rely on.

Who counts as an obliged entity

An obliged entity is any organisation that falls within the scope of the Money Laundering Regulations and deals with trusts. Common examples include:

• banks and building societies;
• insurance companies and investment providers;
• solicitors, accountants, and tax advisers acting in a professional capacity.

Checks they carry out

Obliged entities compare the TRS registration PDF you supply with the information they already hold about the trust and its beneficial owners. They check names, dates of birth, addresses, roles, and the trust’s current status.

They may also verify details against the information held on the Trust Registration Service or ask you to download a fresh proof document if anything appears out of date or inconsistent.

Why existing business links may still prompt requests

Even long‑standing accounts can trigger a fresh request. Banks and other financial firms are required to review their client files periodically as part of ongoing customer due diligence. That means a bank or insurer you have dealt with for years may ask for the same proof again — sometimes more than once.

“Provide the document, confirm the details, and update the register if anything has changed. It is that straightforward.”

Be ready with a current PDF at all times. Preparedness speeds up banking, property transactions, and investment administration — and avoids the frustrating delays that arise when you need to act quickly but cannot produce the right paperwork.

Discrepancy reports explained: minor vs material issues and how to resolve them

A discrepancy query is a routine compliance step — not a penalty notice. Obliged entities are required to check the TRS register against the information they hold. They identify small clerical errors and more serious gaps that may require formal reporting to HMRC.

Examples of minor discrepancies that are usually non-material

Minor differences are often clerical in nature. Examples include “Jon” vs “John”, a missing middle name, “St.” instead of “Street” in an address, or a slightly outdated phone number.

These are usually straightforward to fix. Update the entry on TRS, download a fresh proof of registration PDF, and share it with the bank or adviser who raised the query.

Material discrepancies that can trigger a report to HMRC

Material issues are more serious and carry real consequences. For example, where a trust that should be registered is absent from the register entirely, or where a beneficial owner’s nationality, date of birth, or identity details are missing or incorrect.

Differences in key identity details — date of birth, country of residence, address, or roles held — can trigger a formal discrepancy report from the obliged entity to HMRC.

How trustees can respond

First, update the TRS promptly and correct the details. Then download and provide a refreshed proof of registration to the obliged entity that raised the query.

Acting quickly usually resolves the matter before a formal report is submitted and keeps routine business moving without disruption.

What happens if a material discrepancy is not resolved

If left unresolved, the obliged entity is legally required to submit a discrepancy report to HMRC, which may then investigate further. That can lead to enforcement action, penalties of up to £5,000 per offence, and significant disruption to banking and financial relationships.

“Treat a discrepancy query as a prompt to tidy your records, not a reason to delay. A quick correction now prevents a formal report later.”

New for 2025: mandatory AEOI registration for FI and trustee-documented trusts

If a corporate trustee or professional investment manager looks after trust assets, new AEOI rules may apply to your arrangement — even if all the beneficiaries are UK residents.

Amendments to the International Tax Compliance Regulations in 2025 introduce mandatory AEOI registration for trust arrangements treated as Financial Institutions (FI) or as Trustee-Documented Trusts (TDT). This is separate from the Trust Registration Service and carries its own deadlines and penalty regime.

What changed in the International Tax Compliance Regulations 2025

The key change requires AEOI registration for certain trust arrangements regardless of whether there is a reportable person with foreign tax residency.

Why it matters: the aim is to widen information sharing between tax authorities under the OECD Common Reporting Standard (CRS) and US FATCA regimes. HMRC wants a more complete picture of which trust arrangements hold professionally managed financial assets.

When a trust arrangement is treated as a Financial Institution

A trust arrangement is treated as an FI where it holds financial assets that are professionally managed or administered — for example, where an investment manager manages a portfolio of stocks, bonds, or funds on behalf of the trustees.

Corporate trustees often trigger this classification too. If a company acts as trustee and the trust holds investment assets, the arrangement can meet the FI definition for AEOI purposes. Most family discretionary trusts where the settlor and family members act as trustees and hold a single property — such as the family home in a Family Home Protection Trust — are unlikely to fall within this definition. It mainly affects arrangements with professionally managed investment portfolios.

What is a trustee-documented trust and who reports on your behalf

A Trustee-Documented Trust (TDT) is an arrangement where a reporting Financial Institution acts as trustee and takes responsibility for the AEOI reporting on behalf of the trust it manages.

In some cases, the corporate trustee completes all filings on behalf of the beneficial owners. However, the underlying trust arrangement may still carry direct registration obligations, so trustees should not assume the corporate trustee has covered everything without confirming.

How this differs from the previous “reportable person” approach

Previously, AEOI registration was typically needed only when there was a reportable person — someone with foreign tax residency — connected to the trust.

Now registration can be required even where no one is reportable. That significantly expands the scope and brings more long-standing trust arrangements with professionally managed assets into the AEOI framework for the first time.

“Ask the right question: does our trust fall within the FI or TDT definitions, and have we registered for AEOI? If you are unsure, seek professional advice before the deadline.”

AEOI registration deadlines and penalties trustees should diary now

There are two firm AEOI deadlines every affected trustee should mark in their diary immediately.

Key dates to diarise

The first date is 31 December 2025. Any existing trust arrangement that meets the FI or TDT test must complete its AEOI registration by this date.

The second rule applies going forward: if an arrangement newly qualifies as an FI or TDT during a calendar year, you must register by 31 January following the end of that year. Tie the deadline to the date the arrangement first qualifies, and diarise it straight away.

Penalties for failure to notify

If you do not register by the relevant deadline, an initial penalty of £1,000 can follow. Continued non‑compliance after a formal notice from HMRC can attract daily penalties of up to £300 per day. These are separate from TRS penalties and can apply in addition to them.

Do we need to act?

• Already registered for AEOI: no immediate action needed, but confirm your registration details are up to date.
• Not registered and treated as an FI or TDT: register before the relevant deadline — 31 December 2025 for existing arrangements.
• Unsure: seek professional help promptly from a solicitor or tax adviser, particularly if a corporate trustee, professional investment manager, or cross‑border assets are involved.

“Diary the date, check your status, and register early to avoid penalties. A few minutes of admin now could save £1,000 or more.”

Conclusion

A short, routine review of your trust registration details will save time and reduce risk — both with HMRC and with the banks and advisers you rely on.

To recap the essentials: keep the Trust Registration Service entry accurate, update it within 90 days of any reportable change, and keep the latest digitally signed proof of registration ready to share with any obliged entity that asks for it.

Remember that banks, solicitors, and financial advisers are now required to compare the information they hold with the details on the Trust Register. Treating record accuracy as routine practice — like renewing your household insurance or updating your will — prevents problems before they arise.

For 2025, also check whether your trust arrangement is classified as an FI or TDT for AEOI purposes, and diarise the 31 December 2025 and 31 January deadlines if relevant.

If capacity issues or complex changes make this difficult, seek prompt professional support from a solicitor or trust administration specialist on behalf of the family. As we always say — plan, don’t panic.

Action plan: review the trust file, confirm all beneficial owner and lead trustee data is correct, check Government Gateway access works, and make any needed changes now. Keep a simple, living checklist so the trust arrangement stays compliant year after year. England invented trust law over 800 years ago — the administration has moved online, but the fundamental duty of care remains the same.