We set out the key 2025 changes in plain English so family trustees and advisers can act without delay.
New rules mean your trust registration details must be accurate and updated quickly. If you do not make changes within 90 days, enforcement is possible and fines can be severe.
There is also an international element this year. Certain FI/TDT structures must complete AEOI registration by 31 December 2025. This can apply even where there are no reportable persons.
We will explain the two practical themes: keeping the Trust Register entry correct and having proof of registration ready for banks and advisers.
By the end you will know if the changes affect you, what checks to run, and the next steps to protect your family’s affairs and meet tax obligations.
Key Takeaways
- Update trust registration within 90 days to avoid fines up to £5,000 per offence.
- Certain trusts must complete AEOI registration by 31 December 2025.
- Trustees should review records, log in, and download proof of registration.
- We focus on practical steps for family trustees and lay advisers.
- Act now: simple checks reduce enforcement risk and secure your estate planning.
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 in everyday estate planning when beneficiaries change, a new trustee is appointed, or contact details shift.
Keeping the Trust Register up to date is now practical work, not just form-filling. It helps show you are meeting your duties as a trustee and avoids delays when banks or advisers ask for proof.
Who is most affected
Express trusts and those set up in recent years are the main groups impacted. Trustees who manage family arrangements must check the register more often.
Advisers — solicitors, accountants and tax professionals — will increasingly ask for accurate records before they proceed. That can slow down estate work if you lack proof of registration.
- Common triggers: new trustees, changed beneficiaries, updated contact details.
- Why it matters: proof of registration speeds account openings and investment moves.
- Practical tip: treat your trust file like a household document you refresh regularly.
| Situation | Action required | Who should act | Why it matters |
|---|---|---|---|
| New trustee appointed | Update register within 90 days | Lead trustee | Maintains continuity with banks and advisers |
| Beneficiary changes | Confirm and correct beneficiary details | All trustees | Avoids discrepancies and delays |
| Contact details change | Refresh lead contact and email | Lead trustee | Ensures receipt of notices and proof documents |
| New assets or accounts | Record material changes on the register | Trustee or adviser | Smooths transaction and compliance checks |
For practical guidance on how these rule changes affect estate plans, see our note on how the new inheritance rules affect your family’s. We suggest trustees review records regularly and keep proof of registration ready.
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.
TRS details must be reviewed and updated within 90 days of any change
We must review the trust registration service entry whenever facts change.
Any change in trustees, beneficiaries or contact details needs an update within 90 days. Review is as important as update when dates are unclear.
Proof of registration checks and discrepancy reporting continues to tighten
Since 1 September 2022, obliged entities must ask for proof of registration or an exemption. They also look for mismatches with the held trust register.
If an obliged entity finds material discrepancies, they may have to report them. That can slow or stop account openings.
“Keeping proof ready avoids delays and shows you act responsibly.”
New AEOI registration requirement for certain trusts under CRS/FATCA rules
For 2025, some FI and trustee‑documented (TDT) arrangements must register for AEOI separately. This is different from the trust registration service and has its own deadlines and penalties.
We recommend you identify whether you need TRS actions, AEOI actions, or both. Build a simple compliance rhythm: check, update, download proof, and store it safely.
| Headline | Immediate step | Why it matters |
|---|---|---|
| 90‑day TRS updates | Review records and update registration | Prevents fines and eases business checks |
| Proof and discrepancy checks | Keep digitally signed proof to hand | Speeds account openings and avoids reports |
| AEOI registration | Confirm if FI/TDT rules apply and register | Separate regime with specific penalties |
Trust Registration Service basics you should re-check before making any updates
Start by confirming the basic facts held on the register. Small gaps can turn into material discrepancies. That slows banks and advisers and can create unnecessary reporting.
We suggest a short, practical pre-flight check. Gather the trust deed, appointment or removal paperwork and ID for the people named. This makes updates quicker and more reliable.
What the register holds and why it matters
The register records core information about the trust and its beneficial owners. That includes names, dates of birth, addresses, nationality and the role each person plays.
Who counts as a beneficial owner for TRS purposes
In plain terms, beneficial owners include the settlor, any trustees, beneficiaries and a protector where one exists. For family arrangements, this often means spouses, children or appointed guardians.
“Missing a nationality or incorrect address can be treated as a material discrepancy.”
- Check names and dates of birth match ID.
- Confirm nationality and current address for each owner.
- Have deeds showing trustee appointments or beneficiary changes ready.
| Category | Typical content | Why check it |
|---|---|---|
| Trust details | Name, start date, type | Identifies the held trust record |
| Beneficial owners | Settlor, trustees, beneficiaries, protector | Ensures obliged entities see matching owners |
| Identity details | DOB, nationality, address | Small gaps can trigger a material discrepancy |
For trustees acting as agents, 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 an access code as the final step.
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 the password ready.
When prompted, enter the access code sent to your chosen device or email.
Set up at least two ways to receive codes.
A second phone number or an email backup reduces the risk of being locked out.
Lead trustee identity details you may be asked to confirm
The sign-in flow can ask for the lead trustee name, date of birth and National Insurance number or passport details.
Keep these documents handy to avoid delays.
Maintaining access when circumstances change (new phone, new email, new trustee)
Plan for change. Add a secondary contact method and update the gateway user details if a lead trustee steps down.
If you cannot recover access quickly, seek professional support.
Act early so you can still meet the 90‑day update window and avoid unnecessary complications.
| Issue | Immediate step | Why it matters |
|---|---|---|
| Lost password | Use the gateway user reset and verify identity | Restores access to edit records |
| Changed phone | Add secondary code method before change | Prevents lock-out when codes are needed |
| New lead trustee | Confirm identity details and update access | Ensures continuity for advisers and banks |
How to update the Trust Register within the 90-day deadline
When something in the estate changes, you should log into the register and make the correction within three months. We recommend a simple checklist to keep you on track.
Common changes that trigger an update
Most triggers are straightforward: appointment or removal of trustees, new beneficiaries, and a new lead trustee contact. Record the date the change took effect.
Updating trustee details and lead trustee contact information
Log in with the gateway account and amend names, DOB and contact details carefully. Banks and advisers look here first, so accuracy matters.
Correcting beneficial owner information
Incomplete beneficiary or settlor details cause discrepancy flags. We suggest matching names, dates and addresses to ID before you save edits.
Changes to assets and financial arrangements
Only record material asset changes where they alter how the arrangement is understood externally. If in doubt, update and note why.
What “within 90 days of the date of change” looks like in practice
For changes by deed, the effective date is the deed date. For events like marriage or death, use the event date. Diarise the deadline and keep a short audit trail of what you changed and when.
“Note the date, update the register, and save the proof.”
| Change | Immediate step | Who acts | Example date to record |
|---|---|---|---|
| New trustee | Edit trustee entry and role | Lead trustee | Date on the deed |
| Beneficiary update | Correct name/DOB/address | All trustees | Effective date of change |
| Contact details | Update lead trustee email/phone | Lead trustee | Date of contact change |
| Material asset added | Record relevant financial detail | Trustee or adviser | Date asset acquired |
For step‑by‑step help on registering, see our guide on registering a trust in Britain. Keep a short log and download proof after each edit.
Understanding HMRC penalties and personal liability for trustees
We explain what can happen when register details are not kept accurate. A brief lapse can lead to enforcement action and fines. Trustees need clear, practical steps to reduce risk.
TRS enforcement action and fines of up to £5,000 per offence
Fines can be substantial. For failures to keep the register accurate, penalties may reach up to £5,000 per offence. Repeated or unresolved discrepancies increase the chance of enforcement.
Why trustees can be personally liable for failures (not the trust)
Trustees carry legal duties to manage the arrangement properly. Personal liability means trustees, not the arrangement itself, may have to pay penalties.
This rule exists because breaches are treated as failures in the trustee’s duties. It protects beneficiaries but raises the personal stakes for those acting as trustees.
“Small admin gaps can become big legal and financial problems if left unaddressed.”
Practical risk reduction
- Review records at set intervals and after any change.
- Update the register promptly and download digital proof.
- Keep a short audit note of what changed and when.
- Seek help if changes are complex or you manage multiple arrangements.
| Risk | Consequence | Quick action |
|---|---|---|
| Missed 90‑day update | Fine up to £5,000 per offence | Review and update immediately; save proof |
| Repeated discrepancies | Higher enforcement likelihood | Run a full records check; correct historic errors |
| Unclear responsibilities | Personal liability for penalties | Clarify roles and document decisions |
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 we keep for family affairs.
What it is: a PDF from the trust register showing current details and a digital signature. You can download or print it from the service.
When you will need it: opening accounts, investments, mortgage or pension moves, and whenever an obliged body asks for verification. Providers often request it when forming a new business relationship.
| Action | Tip | Why it helps |
|---|---|---|
| Download after every change | Save with date in filename | Shows you have current information |
| Store securely | Encrypted folder plus one paper copy | Protects family data and access |
| Share smartly | Note who, when and why | Creates an audit trail for advisers |
Keep the latest PDF and update it after edits. A fresh copy avoids questions about mismatched records and speeds routine dealings. For how to manage the online account, see the official guidance on managing the registration service.
“A current digitally signed PDF prevents delays and shows you act responsibly.”
Working with “obliged entities” since September 2022: what they will ask for
Organisations that provide banking or financial services now routinely request registration evidence before they proceed. This rule began in September 2022 and affects many everyday relationships.
Who counts as an obliged entity
An obliged entity is any body that opens or manages financial accounts for you. Common examples are:
- banks and building societies;
- insurance companies and investment providers;
- solicitors, accountants and tax advisers acting for clients.
Checks they carry out
Obliged entities compare the registration PDF you supply with the information they already hold. They will check names, dates, addresses and roles.
They may also confirm details against the held trust register or ask for a fresh download if anything looks out of date.
Why existing business links may still prompt requests
Even long‑standing accounts can trigger a request. Firms review files periodically to meet their compliance duties. That means a familiar bank or insurer might ask for the same proof again.
“Provide the document, confirm the details, and update the register if anything has changed.”
Be ready with a current PDF. Preparedness speeds banking, mortgage and property work and cuts delays when you need to act fast.
Discrepancy reports explained: minor vs material issues and how to resolve them
Discrepancy queries are a routine compliance step — not a penalty notice. Obliged entities check the register against what they hold. They identify small errors and more serious gaps that may need reporting.
Examples of minor discrepancies that are usually non-material
Minor differences are often clerical. Examples include “Jon” vs “John”, missing middle names, or “St.” instead of “Street”.
These are usually easy to fix. Update the entry, download a fresh PDF and share it with the bank or adviser.
Material discrepancies that can trigger a report to HMRC
Material issues are more serious. For example, where a trust needs registered but is not on the register, or a beneficial owner lacks nationality or date of birth.
Differences in key details — DOB, country of residence, address, email or phone — can also trigger a formal report.
How trustees can respond
First, update the TRS promptly and correct the details. Then download and provide refreshed proof of registration to the obliged entity.
Acting quickly usually stops a report and keeps routine business moving.
What happens if a material discrepancy is not resolved
If unresolved, the obliged entity must submit a discrepancy report and HMRC may investigate. That can lead to enforcement steps and possible penalties.
“Use a discrepancy query as a prompt to tidy records, not a reason to delay.”
| Issue | Quick action | Outcome |
|---|---|---|
| Minor name/address error | Correct and resend PDF | Usually closed |
| Missing owner details | Fill gaps, confirm ID | Avoids formal report |
| Unregistered arrangement that need registered trs | Register trust and send proof | Prevents enforcement |
New for 2025: mandatory AEOI registration for FI and trustee-documented trusts
If a corporate trustee or professional manager looks after investments, new AEOI rules may apply.
Amendments to the International Tax Compliance Regulations 2025 introduce mandatory AEOI registration for arrangements treated as Financial Institutions (FI) or as trustee-documented trusts (TDT).
What changed in the International Tax Compliance Regulations 2025
The change requires registration for certain arrangements regardless of whether there is a reportable person.
Why it matters: the aim is wider information sharing under the OECD CRS and US FATCA regimes.
When a trust is treated as a Financial Institution
A trust is treated as an FI where it holds financial assets that are professionally managed.
Corporate trustees often trigger this test too. If a company acts as trustee, the arrangement can be an FI for AEOI purposes.
What is a trustee-documented trust and who reports on your behalf
A trustee-documented trust (TDT) is where a reporting FI acts as trustee and reports for the trusts it manages.
Sometimes the corporate trustee completes filings on behalf of the beneficiaries. But the arrangement may still carry direct obligations.
How this differs from the previous “reportable person” approach
Previously, registration was typically needed only when there was a reportable person with foreign tax residency.
Now registration can be required even where no one is reportable. That expands scope and brings more long-standing family arrangements in.
“Ask the right question: do we fall within the FI/TDT definitions, and have we registered for AEOI?”
| Trigger | Who may report | Practical step |
|---|---|---|
| Professionally managed financial assets | Arrangement treated as FI | Confirm AEOI registration status |
| Corporate trustee in place | Corporate trustee may report on behalf | Check corporate filings and responsibilities |
| Trustee‑documented trust | Reporting FI acts as trustee | Clarify whether separate registration is needed |
AEOI registration deadlines and penalties trustees should diary now
There are two firm AEOI deadlines every trustee should mark in their diary right now.
Key dates to diarise
The first date is 31 December 2025. Any existing arrangements that meet the FI or TDT test must complete registration by then.
The second rule is the 31 January deadline. If an arrangement newly qualifies during a calendar year, you must register by 31 January after year-end. Tie the deadline to the date the arrangement first qualifies as an FI or TDT.
Penalties for failure to notify
If you do not register, an initial £1,000 charge can follow. Continued non‑compliance can attract up to £300 per day after a notice.
Do we need to act?
- Already registered: no immediate action.
- Not registered and treated as an FI or TDT: register before the relevant date.
- Unsure: seek professional help if a corporate trustee, professional manager or cross‑border assets are involved.
| Situation | Deadline | Action |
|---|---|---|
| Existing arrangements | 31 December 2025 | Complete registration |
| Newly qualifying in year | 31 January after year end | Register within the rule |
| Already registered | N/A | Keep record; no repeat filing |
“Diary the date, check status, and register early to avoid penalties.”
Conclusion
A short, routine review of registration details will save time and reduce risk.
We recap the essentials: keep the trust register entry accurate, update the trust registration service within 90 days and keep the latest proof of registration ready to share.
Remember that banks and advisers compare what they hold with the held trust register. The registration service manual guides those checks, so treat record accuracy as routine practice.
For 2025, check whether your arrangement is an FI or TDT for AEOI and diarise the 31 December / 31 January deadlines if relevant.
If capacity or complex changes make this hard, seek prompt professional support on behalf of the family.
Action plan: review the file, confirm beneficial owners and lead trustee data, check Government Gateway access and make any needed changes now. Keep a simple, living checklist so the arrangement stays compliant year after year.