Trust Registration Service: How to Register and Who Needs to Comply

Registering with the Trust Registration Service is a key requirement for many UK trusts. This guide answers common questions about the Trust Registration Service, including who can register a trust, how to access the Trust Registration Service, and when the Trust Registration Service started. If you are a trustee or considering setting up a trust, understanding the trust registration process is essential.

What is the Trust Registration Service (TRS)?

The TRS is an online register introduced in 2017 and updated in October 2020. It requires most UK trusts — even those without a tax liability — to register. The deadline for registration was 1 September 2022, unless a trust qualifies for an exemption, or 90 days from creation of a trust.

Who Needs to Register a Trust with the TRS?

• Taxable trusts: Must be registered within 90 days of becoming liable for UK tax.
• Non-taxable trusts: Most UK non-taxable express trusts (with some exceptions) must register within 90 days of creation.

Which Trusts Are Exempt from Registration?

Some trusts are excluded from the requirement to register with the Trust Registration Service if they do not have a tax liability, including:

• Charitable trusts
• Life insurance policy trusts (payouts on death, illness, or disability)
• Trusts holding assets for UK-registered pension schemes
• Pilot trusts (with less than £100, set up before 6 October 2020)
• Will trusts (if wound up within two years of death)
• Certain co-ownership trusts (holding jointly owned property as ‘tenants in common’)
• Trusts for vulnerable persons, bereaved minors, and personal injury trusts
• Trusts for Junior ISAs, Child Trust Funds, or bank accounts for minors

What Are My Responsibilities as a Trustee?

As a Trustee, you must:

• Register the trust with the Trust Registration Service if required
• Maintain accurate records of trustees, beneficiaries, and assets
• Update the TRS within 90 days if any trust details change (e.g., new trustees, beneficiaries, or assets)

What is a Lead Trustee?

A Lead Trustee is the main point of contact with the TRS. This individual is responsible for the registration unless an agent is appointed to handle the process.

How to Register a Trust with the TRS

To complete the TRS registration process, you need to provide:

• Trust details – Name, creation date, and confirmation of express trust status
• Trustee details – Name, date of birth, nationality, residence, and National Insurance number (for the Lead Trustee)
• Settlor details – Name, date of birth, date of death (if applicable), nationality, and residence
• Beneficiary details – Information on named and class beneficiaries
• For taxable trusts – Additional details about the trust’s assets

What Happens if I Don’t Register a Trust with the TRS?

Failing to register a trust with the TRS (unless exempt) or update the registration can lead to penalties of up to £5,000. HMRC has started issuing warning letters for unregistered trusts, so compliance is crucial.

How Can We Help?

Navigating the Trust Registration Service can be complex. Whether you need assistance in registering a trust with HMRC or ensuring compliance, our team is here to help. Contact us today to ensure your trust meets all legal requirements.