We explain, in plain English, how to follow the official route. This short guide covers the Trust Registration Service (TRS) on GOV.UK and what trustees must do to comply with anti‑money‑laundering rules and to obtain a Unique Taxpayer Reference (UTR) when needed.
Most trustees are ordinary people holding family property, investments or funds for children or grandchildren in a trust arrangement. You will see why accuracy matters — particularly the trust name and the creation date on the trust deed. HMRC can impose penalties of up to £5,000 for failing to register on time or to keep details up to date.
Let us set expectations from the start. This is a registration process, not a tax filing — though the two often become linked once a trust generates taxable income or gains. Before you begin, gather your trust deed, lead trustee information and a summary of the trust assets.
For step‑by‑step official guidance see the GOV.UK guidance. If you prefer practical help from specialist advisers, read our expert notes at MP Estate Planning.
Key Takeaways
- Use the Trust Registration Service on the GOV.UK website to complete your formal trust registration.
- Trustees usually register to meet anti‑money‑laundering obligations under the 5th Money Laundering Directive or to obtain a UTR for tax purposes.
- Keep the trust’s name and creation date accurate — they must match your trust deed exactly to avoid HMRC queries and potential penalties.
- Registration is a separate step from filing a trust tax return (SA900), but the two become linked if the trust is taxable.
- Gather trustee, settlor and asset details before you start — having everything to hand makes the process considerably faster.
Understanding the Trust Registration Service and why registration matters
The Trust Registration Service creates a record of who holds and benefits from assets held in trust arrangements — and understanding why that matters is the first step.
The Trust Registration Service (TRS) is a government-held register that exists primarily to support anti‑money‑laundering requirements under the 5th Money Laundering Directive. It is not solely about tax. The service helps regulators verify who controls trust assets and where benefits flow, which in turn helps prevent financial abuse and money laundering.
Importantly, the TRS register is not publicly accessible in the way Companies House is. Only persons with a legitimate interest can request limited information — so your family’s details are not on open display.
Below we explain who appears on the register and the everyday roles you will need to identify before you start.
When a trust must appear on the register
Since 6 October 2020 (expanded from the earlier taxable-only rules), all UK express trusts must be registered on the TRS — even if no tax is due. If the trust arrangement meets the legal definition of an express trust, it is registerable unless a specific Schedule 3A exclusion applies. This was introduced as part of the UK’s implementation of the 5th Money Laundering Directive — reflecting a registration obligation that now applies to all express trusts, not just those with a tax liability.
Who does what?
We use plain language:
- Settlor – the person who creates the trust arrangement and transfers assets into it.
- Trustees – the people who look after those assets. In English law, trustees are the legal owners of the trust property. A trust is not a separate legal entity — it is a legal arrangement, and the trustees hold and manage the assets on behalf of the beneficiaries. England invented trust law over 800 years ago, and this distinction between legal and beneficial ownership remains the foundation of how trusts work today.
- Beneficiaries – those who may benefit from the trust assets. In a discretionary trust (the most common type for family asset protection), no individual beneficiary has a right to income or capital — instead, the trustees decide who receives what and when.
One trustee must be named as the lead trustee. That person is the main contact with HMRC, receives reference numbers and must keep details current. Legally, however, all trustees remain equally responsible for the trust’s administration and compliance.
| Role | Main duty | Practical note |
|---|---|---|
| Settlor | Creates the trust arrangement and transfers assets into it | Usually a family member — can also serve as a trustee |
| Trustees | Manage assets and make decisions on behalf of beneficiaries | Minimum of two trustees required; all share legal responsibility |
| Lead trustee | Main point of contact with HMRC and other institutions | Keeps contact details current and receives reference numbers |
If you want practical help naming people and completing details, see our guide for trustees.
Who must register a trust with HMRC in the UK
Knowing which trust arrangements must appear on the register helps trustees avoid unexpected penalties — and understanding the rules is simpler than many people assume.
All UK express trusts generally must be registered on the TRS, even if no tax is owed. This includes the most common family trust types — discretionary trusts, bare trusts, and interest in possession trusts. The only exceptions are those that fall within the specific Schedule 3A exclusions (covered in the next section).
Non-UK arrangements with UK connections
Certain non-UK express trusts become registerable when they acquire UK land or property. They are also caught if a UK-resident trustee enters into a business relationship with a UK-regulated financial institution — for example, opening a bank account or investment platform in the UK.
When tax makes a trust reportable
Taxable events also trigger a registration obligation. These include liabilities for income tax, capital gains tax (CGT) and inheritance tax (IHT). Stamp duty charges — including Stamp Duty Land Tax (SDLT), Stamp Duty Reserve Tax (SDRT), and the devolved equivalents (Land and Buildings Transaction Tax in Scotland, Land Transaction Tax in Wales) — also create a registration requirement.
Common trust assets can create these liabilities. A buy-to-let property generates rental income taxed at the trust rate of 45% (on non-dividend income above the first £1,000, which is taxed at the basic rate). A share portfolio can create capital gains, taxed at 24% for residential property and 20% for other assets. Even cash savings held within the trust arrangement can lead to a trust Self Assessment (SA900) filing obligation.
Practical tip: even if you believe your trust is non-taxable, circumstances can change — a property sale, rental income or even bank interest could tip it into being taxable. For help, see our guide to protect your family’s future.
Which trusts are excluded from registration (Schedule 3A trusts)
Some family trust arrangements are excluded from immediate registration, but that exclusion can fall away if a UK tax liability arises.
What Schedule 3A means in practice: these are specific categories of express trusts that are excused from the TRS while they remain free of UK tax liability. The exclusions are set out in Schedule 3A of the Money Laundering Regulations.
Common excluded arrangements
- Will trusts used during estate administration — excluded for up to two years after the date of death, provided the personal representatives are still winding up the estate.
- Registered pension scheme trusts where payments arise under HMRC-approved pension rules.
- Life insurance arrangements that pay out on death, illness or disability — provided no other trust activity occurs. This is worth noting: a life insurance trust — such as those set up to keep a payout outside the estate for inheritance tax purposes — can often be excluded from TRS registration entirely, yet still delivers significant IHT savings for the family.
- Pilot trusts set up before 6 October 2020 with assets of under £100 at that date.
- Charitable trusts already registered with the Charity Commission for England and Wales.
When exclusion ends
Co‑ownership arrangements (such as tenants in common holding property) and many commercial or transactional trust arrangements start as excluded — but they become registerable the moment a UK tax charge arises or their circumstances change.
If you hold property, land or capital for others, do not assume you are excluded. Check the trust deed carefully and take specialist advice rather than guessing about your position. The boundaries between excluded and registerable can be surprisingly fine.
| Excluded type | Typical reason for exclusion | When it becomes registerable |
|---|---|---|
| Will trusts | Short‑term estate administration (up to 2 years after death) | If IHT, income tax, CGT or other tax liability arises, or if the 2-year period expires |
| Pension schemes | Payments under HMRC-registered pension rules | If trust activity falls outside the registered pension rules |
| Life insurance trusts | Policies paying out on death, illness or disability | When benefits create a taxable event or other trust activity occurs |
| Pilot trusts <£100 | Small funds held before 6 Oct 2020 | Becomes registerable if later funded above £100 or a tax liability arises |
| Co‑ownership | Tenants in common holding property | When income, capital gains or land tax charges arise from the arrangement |
Registration deadlines and how to know when to register
Timings matter: the date a trust was created and whether it has a tax liability determine which deadline applies to your registration.
Non-taxable trusts created after 6 October 2020
For non-taxable trust arrangements created after 6 October 2020, trustees must register within 90 days of creation. If the trust later becomes liable for tax, it must also be registered within 90 days of the date that tax liability first arises.
Taxable trusts created on or after 6 April 2021
If a trust first becomes liable for UK tax from 6 April 2021 onwards, the same 90-day window applies — running from the date the liability arises. This applies to income tax, CGT, IHT and stamp duty charges alike.
Older taxable trusts: the 5 October and 31 January dates
Trusts that existed and had tax liabilities before the expanded TRS rules follow a different timetable. A first-time income tax or CGT liability typically requires registration by 5 October following the end of the tax year in which the liability arose.
Ongoing liabilities and subsequent updates generally follow the 31 January filing deadline that aligns with the Self Assessment timetable.
Missed deadlines and penalties
Failing to meet the deadline can lead to penalties of up to £5,000. HMRC has shown willingness to enforce these, particularly where trustees have been clearly negligent. The penalties increase with the seriousness and duration of the failure.
We recommend building a simple timeline: note the trust’s creation date, when assets were transferred in, when the first income or gains arose, and when tax first became due. This creates a clear audit trail. Plan, don’t panic — a few minutes of record-keeping now saves real trouble later.
| Situation | Key date | Action required |
|---|---|---|
| Non-taxable trust (post 6 Oct 2020) | Creation date, or date first tax liability arises | Register within 90 days |
| Taxable trust (from 6 Apr 2021) | Date tax liability arises | Register within 90 days |
| Older taxable trust | First IT/CGT liability or ongoing case | 5 October for first liability; 31 January for ongoing updates |
HMRC register trust online: what you need before you start
A little preparation saves a lot of time: collect the key details the TRS system requires before you begin the online process.
Trust basics to gather
- The exact name of the trust arrangement and the date it was created — both must match the trust deed precisely.
- Confirmation that it is an express trust and details of any UK land or property the trust holds.
- A copy of the trust deed and any supplemental deeds or amendments, so names, dates and asset descriptions match exactly.
Lead trustee information
Have the lead trustee’s full legal name, date of birth, current residential address, National Insurance number and contact details ready. A working email address and phone number help avoid delays with security codes.
Settlor and beneficiary details
Record the settlor’s full details, including their date of death if applicable. For living settlors, the TRS will ask about their mental capacity — have the answer ready.
List all named beneficiaries. If the trust deed uses classes of beneficiaries (for example, “future grandchildren” or “all descendants”), note that you must keep separate internal records if any single class has more than 25 identifiable people. You do not need to list each individual on the TRS itself — but you must be able to produce the list if HMRC asks.
Non‑UK specifics
If the trust arrangement has a UK business relationship, holds UK land, or controls an offshore company, prepare the company details (including any overseas registration numbers) and a description of the nature of the connection.
| Item | Why it matters | Example |
|---|---|---|
| Trust name & creation date | Must match the trust deed exactly to avoid HMRC queries | The Smith Family Settlement, 12 March 2021 |
| Lead trustee | Receives reference numbers and all HMRC correspondence | Full name, DOB, NI number, address, email |
| Beneficiaries | Named individually or as classes; internal records required if 25+ in a class | Named: John Smith; Class: “grandchildren of the settlor” |
Setting up the right Government Gateway account for trust registration
Set up the correct government account before you try to submit any details — using the wrong type of login will stop the process before it starts.
This section explains the small but vital differences between Gateway account types. Getting the right account saves time and avoids the frustration of having to start over.
Why you need an Organisation Government Gateway account
You must use an Organisation Government Gateway account for trust registration. An Individual Gateway ID will not work — the TRS system will not allow you to proceed with a personal login.
This is the rule that catches people out most often. If you start with your personal Individual Gateway (the one you might use for your own Self Assessment), you will be blocked when the system asks for an Organisation ID. You will then need to create a new account and start again.
One Gateway account per trust: plan ahead
HMRC expects a separate Organisation Gateway ID for each individual trust you manage. If you are a trustee of multiple family trusts — which is common where parents have set up trusts for different children — you will need a separate account for each one.
Plan distinct email addresses and logins for each trust. This keeps records clean, avoids mixing up reference numbers, and prevents the confusion that comes from managing multiple trusts through a single account.
Security codes and keeping your Gateway ID safe
During sign-up you will need an email address, a contact name and a phone number. The service then generates your Government Gateway User ID.
You will receive security codes by text message or automated phone call. Keep your phone number up to date — if you change your number and forget to update it, you will be locked out of the account.
- Store your Gateway credentials in a secure place (a password manager is ideal) and ensure at least one other trustee knows where they are kept.
- Use a stable phone number for receiving security codes, or set up alternate recovery options during the registration process.
- If a trustee steps down or is replaced, review and update account access promptly to avoid future lockouts.
| Step | Why it matters | Quick tip |
|---|---|---|
| Create an Organisation account | Required to access the Trust Registration Service | Do not use your personal Individual Gateway login |
| Assign one Gateway ID per trust | Prevents mixed records and missing references | Use a separate email address for each trust |
| Secure codes and backup access | Protects the account and enables evidence downloads | Record recovery options and share securely with co-trustees |
How to register a trust on the TRS: step-by-step online process
Begin the TRS process on GOV.UK and take your time to choose the correct service option. We guide you through the key screens so you do not accidentally end up in the trust management area (which is for existing registrations) instead of the new registration section.
Starting the registration on GOV.UK
Sign in with your Organisation Government Gateway ID and navigate to the TRS section labelled for new registrations. Confirm you have selected the correct option — “Register a trust” rather than “Maintain a trust” — before you proceed. Choosing the wrong option is a common mistake that costs time.
Entering people and roles accurately
Enter all trustees, the lead trustee, settlors and beneficiaries exactly as their names appear on the trust deed. Small mismatches — middle names, dates of birth, postcodes or country names — are the most common cause of HMRC queries and delays.
Practical tip: have the trust deed open beside you and cross-reference each name and date as you enter it. What seems like a minor typo can trigger correspondence from HMRC that takes weeks to resolve.
Adding assets and values for taxable cases
If the trust arrangement is taxable, the TRS will ask you to add asset categories and provide sensible estimated values. You do not need a formal valuation at this stage — a reasonable estimate is sufficient. Common categories include:
| Category | Example |
|---|---|
| Property or land | Family home, buy-to-let property, agricultural land |
| Shares | Quoted shares, unquoted private company holdings |
| Business interests | Partnership shares, LLP interests, limited company shares |
| Money & other assets | Bank accounts, cash, jewellery, art, vehicles |
Submitting and saving evidence
Before clicking submit, carefully review all details against the trust deed. Once submitted, immediately download and securely store the confirmation screen and any reference numbers. These act as proof of registration if a bank, solicitor or financial adviser asks for evidence — which they increasingly do as part of their own anti‑money‑laundering checks.
After registration: UTRs, URNs and proof of registration
Completing the online registration starts a short follow-up process that results in formal reference numbers being issued — either by post or via your online account.
What taxable cases receive
Taxable trust arrangements receive a Unique Taxpayer Reference (UTR). This is posted to the lead trustee’s registered address, typically within 15 working days. The UTR is essential — you will need it to file the trust’s Self Assessment tax return (SA900) and for any correspondence with HMRC about the trust’s tax affairs.
Non-taxable outcomes
For non-taxable trusts, HMRC does not issue a UTR because there is no tax return to file. Instead, the trust receives a Unique Reference Number (URN) which you can view by logging back into your TRS account. Note the URN and store it with the trust deed.
Using and proving registration
Banks, building societies and other regulated persons increasingly ask for proof of TRS registration when you open trust bank accounts, change signatories or set up investment accounts. This is part of their own anti‑money‑laundering obligations. You can download an “evidence of registration” PDF directly from your TRS account.
- Keep the UTR or URN together with the trust deed and the lead trustee’s contact details in a single secure file.
- Provide the evidence of registration PDF to banks, solicitors or financial advisers whenever they request it.
- Store a clean copy of all references securely so that replacement or successor trustees can access the information quickly if needed.
| Situation | What you receive | Typical timing |
|---|---|---|
| Taxable trust arrangement | Unique Taxpayer Reference (UTR) | Posted to lead trustee within 15 working days |
| Non-taxable trust arrangement | Unique Reference Number (URN) viewable in your TRS account | Available immediately after logging back in |
| Proof for banks and advisers | Evidence of registration PDF | Available to download from TRS account at any time |
Claiming, maintaining and updating your trust registration
Claiming the registration record links the lead trustee to the trust so the TRS account can be managed securely going forward.
How the lead trustee claims a registered trust
The lead trustee must claim the TRS entry using their Organisation Government Gateway login and the unique reference (URN or UTR) received after registration.
Keep that reference safe. It is how HMRC contacts the lead trustee and how the system verifies who has authority to view and update the registration.
Security checks and practical issues
Expect straightforward identity verification questions. The system may ask for personal details of the lead trustee and information about another person connected to the trust arrangement.
Three incorrect security answers can lock the account for approximately 30 minutes. If that happens, simply wait and try again — or use the recovery options you set up during initial registration. This is a security feature, not a permanent block.
Keeping details current (the 90‑day rule)
Trustees must update the TRS within 90 days of any material change. This includes changes to trustees (appointment or retirement), new or removed beneficiaries, changes of address, and any other significant updates to the information held on the register.
We advise noting changes as they happen and diarising a regular review — perhaps alongside your annual trustee meeting. Leaving updates until the last minute risks missing the deadline and incurring penalties of up to £5,000.
Annual declarations and tax deadlines
Taxable trust arrangements must file an annual declaration through the TRS, confirming that the information held is still accurate. This is due by 31 January each year. For taxable trusts, this sits alongside the SA900 trust tax return and any income tax or CGT payments due on the same date.
Non-taxable trusts do not need to file an annual declaration, but trustees should still review the TRS record annually and update it within 90 days if anything has changed.
Working with an agent
You can authorise a solicitor, accountant or professional trust administrator to manage the TRS on your behalf. This is particularly useful for complex trust arrangements or where trustees prefer to delegate the administrative burden. However, authorising an agent does not remove trustee responsibility — trustees remain legally accountable for the accuracy of the information on the register.
- Claiming links the TRS account to the lead trustee using their Government Gateway login plus the URN or UTR.
- Security checks may temporarily lock you out after three wrong answers — wait 30 minutes and try again.
- Update any material changes within 90 days to avoid penalties of up to £5,000.
- Annual declarations for taxable trusts are due by 31 January each year.
Conclusion
A clear checklist and a steady approach turn what feels like a fiddly admin task into a straightforward one-off job.
Start by confirming whether your trust must appear on the TRS register and check whether any Schedule 3A exclusions apply to your situation. Gather your trust deed, settlor details and beneficiary information, then use the official Trust Registration Service to complete the process.
Two practical steps matter most: set up an Organisation Government Gateway account (not a personal one), and meet the relevant deadline — which for most trusts is the 90-day rule from creation or from a tax liability arising. After submission, keep your reference numbers safe and download the evidence of registration PDF for future use with banks and advisers.
If you are unsure about complex exclusions, non‑UK connections, or what triggers a tax liability within a trust, follow the official guidance or seek specialist advice. The law — like medicine — is broad, so working with a specialist in trust law makes a real difference. For step‑by‑step help see the GOV.UK page to manage your trusts via the manage your trusts registration service.
Take it one step at a time — a clear, compliant trust registration protects your family’s assets and ensures trustees can act without unnecessary delays.