Deadline of 31 December 2025 for trusts to register under AEOI regulations
Members acting for trust clients should take urgent action to check whether any registrations are required with HMRC by 31 December 2025.
Trusts and other entities classified as either UK reporting financial institutions or UK trustee-documented trusts now have a one-off requirement to provide information to HMRC through the portal. This is separate and in addition to the trust registration service.
Until now, trusts classified as financial institutions may not have had any need to register if the settlor, trustees and beneficiaries were UK based. This changed with the introduction of the International Tax Compliance (Amendment) Regulations 2025, which came into effect in July 2025.
Who needs to register
HMRC’s International Exchange of Information Manual provides detailed guidance on the background to the measures, who needs to register and how entities are classified.
In essence, the following trusts are now likely to need to register:
- Financial institutions - a trust will be a financial institution if more than 50% of its income comes from financial assets (for example a share portfolio) and its assets are managed by a fund manager under a discretionary mandate.
- Trustee-documented trusts – these are trusts managed by financial institutions i.e. professional trustees.
Registration deadline
Trusts will need to review HMRC’s guidance, confirm if they meet the definition of a financial institution and if so, register by 31 December, or by 31 January following the calendar year in which they first come into scope.
HMRC can charge a £1,000 penalty for late registration, increasing to £300 per day if the failure to register continues beyond the issue of the first penalty notice. Penalties can also be charged for inaccuracies in the reporting and for failure to notify individual reportable persons that their information will be reported.
Registration process
Registration must be completed through HMRC’s AEOI portal using an organisation’s government gateway account.
Note that once a registration has been submitted, the account will be frozen for 24 hours to allow for processing, preventing further submissions in that period. As a workaround, it should be possible to complete up to 250 trust registrations in each submission.
CIOT comments
CIOT are aware that the registration requirements have not been widely publicised and HMRC guidance was updated only recently. HMRC have rejected a proposal for an extension to the deadline due to the international nature of the obligations. However, we have been advised that penalties will not be issued automatically. HMRC have stated: if you represent Financial Institutions or Trustee-Documented Trusts, please ensure they are registered by this deadline, or as soon as possible afterwards. Late registration penalties will not apply if you have a reasonable excuse for any delay in registering. If you need any support with registering, or think you will be unable to meet the deadline, please email [email protected].