UK Trust Registration Service: Do You Need to Register Your Trust?

HMRC updated its guidance on the Trust Registration Service (TRS) on 30 June 2026. If you're a trustee or a beneficiary wondering whether your trust needs to be on the register, the answer hinges on a few specific tests — and missing a deadline can mean a compliance breach under the Money Laundering Regulations 2017. Here's what you need to know.

Why the TRS Exists

The Trust Registration Service is the UK government's mechanism for bringing trusts inside the anti-money laundering framework. It's run by HMRC, and registering gives the trust a Unique Taxpayer Reference (UTR) where one is needed. The obligation sits in Schedule 3A of the Money Laundering Regulations 2017, which also defines which trusts are exempt.

The core AML purpose

Registering a trust makes its beneficial owners — settlors, trustees, beneficiaries, and protectors — visible to HMRC and, in certain circumstances, to third parties carrying out due diligence. That transparency is the point. If your trust holds crypto assets, property, or other investments and has any UK tax exposure, it almost certainly needs to be on the register.

Which Trusts Must Register

Not every trust has to register, but the scope is broad. You must register if your trust falls into any of the following categories.

Trusts with a UK tax liability

Any UK resident trust that becomes liable for Income Tax, Capital Gains Tax, Inheritance Tax, Stamp Duty Land Tax, Stamp Duty Reserve Tax, or Land and Buildings Transaction Tax on UK assets or income must register. This applies even if a relief removes the actual tax bill — if you or your client needs to claim that relief through a Self Assessment return, registration is still required.

Non-resident trusts acquiring UK land

A non-UK resident trust also falls within scope if it acquired an interest in UK land before 6 October 2020 and still held that land or property on 30 June 2026. If your overseas trust has UK property and that land was still held at that date, you need to act. Separately, non-resident trusts with at least one UK-resident trustee that enter a business relationship within the UK must also register.

Trusts needing a UTR

If a trust needs a Unique Taxpayer Reference for any reason — for example, to report non-resident Capital Gains Tax — it must register regardless of the other tests.

Trusts That Don't Need to Register (Schedule 3A)

Schedule 3A of the Money Laundering Regulations 2017 carves out a list of excluded trusts, often called Schedule 3A trusts. You don't have to register if your trust is one of these — unless it has a UK tax liability, in which case registration is required anyway.

Common excluded trust types

The excluded categories include:

• Life insurance policy trusts that only pay out on death, illness, or disability
• Trusts held for a registered UK charity, or a charity not required to register under the Charities Act 2011
• Will trusts set up on death that take assets from an estate and close within two years of the date of death
• Co-ownership trusts holding property or assets jointly owned as tenants in common
• Trusts holding client money, securities, or other assets incidental to the business of a relevant supervised person
• Trusts created by deed of variation as part of estate management
• Property co-ownership trusts that ceased to be exempt because a trustee died (including statutory trusts under section 34(2) of the Law of Property Act 1925)

There's also a settlor-linked exclusion for certain express trusts that meet all the qualifying criteria — but this applies to only one trust per settlor. If a settlor has created two or more trusts that would otherwise qualify, only one gets the exclusion.

Understanding where your trust sits in the UK AML framework matters beyond the TRS. Our coverage of HMRC economic crime supervision and what it means for you sets out the broader supervisory picture.

Registration Deadlines

Getting the timing right is critical. The deadlines vary depending on when the trust was created and what triggered the obligation.

Trusts created after 6 October 2020

Register within 90 days of the trust being set up, or of it becoming liable for tax — or by 1 September 2022, whichever is later. Most new trusts created now will have a 90-day window from creation or the date the tax liability arose.

Trusts created before 6 October 2020

The general registration deadline for these trusts was 1 September 2022. If yours wasn't registered by then and should have been, you're already out of time and should take advice immediately.

Tax-specific deadlines

Where a trust becomes liable to Income Tax or Capital Gains Tax for the first time, the deadline is 5 October in the tax year after the one in which that liability first arose. For other taxes — including Inheritance Tax — the deadline is 31 January in the tax year following the one in which the liability arose. For trusts that acquired UK land before 6 October 2020 and still held it on 30 June 2026, the registration deadline is 1 September 2027. Note that the TRS currently does not allow registration of these trusts yet; HMRC has confirmed it will provide an update when that becomes possible.

Practical Steps

If you've worked through the tests above and concluded your trust must register, the process runs through the Trust Registration Service on GOV.UK. You'll need details of the trust's structure, its assets, and the identities of all relevant parties. If you're unsure whether a particular product or arrangement counts as a trust that requires registration, HMRC recommends checking with a solicitor, accountant, or financial adviser.

Crypto assets held in a trust structure are no different from any other asset class for TRS purposes: if there's UK tax exposure, registration applies. For context on how UK regulators approach financial crime supervision more broadly, see our piece on UK AML obligations in practice.

Source: HMRC / GOV.UK