Trust registration changes: expanded scope and new exemptions

The government has announced changes to the Trust Registration Service (TRS) as part of its response to the consultation it ran on improving the effectiveness of the Money Laundering Regulations (MLRs).

These changes aim to target registration requirements more effectively at higher-risk trusts, while simplifying compliance and improving consistency for lower-risk trusts.

What is the Trust Registration Service?

The TRS is an online service managed by HMRC through which the vast majority of UK trusts and many UK-connected overseas trusts must provide information about the trust’s settlor, trustees, beneficiaries, and potentially assets, to meet anti-money laundering obligations. It’s also the only way to register a trust with HMRC and obtain a Unique Taxpayer Reference (UTR).

For more on the existing rules on who must register and how, the annual compliance obligations and the penalties for non-compliance see our Trust Registration Service guide.

Key changes to the TRS requirements

Based on the government’s Improving the effectiveness of the Money Laundering Regulations Consultation response published in July 2025, from a date not yet known, but expected to be later this year, the TRS obligations are changing.  

Expansion of scope to non-UK trusts holding UK property

There will be a requirement for all non-UK trusts that acquired UK land and property before 6 October 2020 to register, providing they still have an interest in UK property at the date the amendment to the MLRs come into force. Until the change, non-UK express trusts with no UK trustees that hold UK land and property acquired before 6 October 2020 are not required to register with the TRS unless they become taxable in the UK.

In addition, all non-UK express trusts with no UK trustees that currently own UK land or property will be brought within the data sharing rules of the TRS. This means HMRC may share information held on the TRS about such trusts with some third parties. Information will only be shared if the person can show they have a legitimate interest such as they are investigating money laundering or terrorist financing.

New de minimis exemption for small non-taxpaying trusts

To reduce the compliance burden for small, low risk trusts, a new exemption will apply to trusts created on or after the legislation comes into force. To qualify, a trust must:

• Not be liable for relevant UK taxes,
• Not own or have any interest in UK land or property,
• Have accumulated assets worth no more than £10,000,
• Have annual income of no more than £5,000, and
• Have ‘appreciable’ non-financial assets (eg art, jewellery or antiques) of no more than £2,000.

Once a trust exceeds any of the thresholds, the trust would become registrable and remain so.

Scottish survivorship destination trusts will also be exempt from the requirement to register. These trusts are created to revoke a survivorship clause in property owned jointly, redirecting the interest to a different beneficiary.

Alignment of reporting for trusts arising from death

As already applies to will trusts created on death, the following trusts will be exempt from TRS registration for two years following the death of the settlor:

• Co-ownership property trusts,
• Trusts created under s34 Trustee Act 1925 (which provides that land held by more than four people is to be held in trust) that have become registerable because of the death of a trustee, and
• Trusts created by deed of variation during the administration of a deceased person’s estate.

Where these types of trusts are currently required to be registered the deadline is 90 days from creation.

What next?

These changes will only apply once the government has amended the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. A draft Statutory Instrument is expected in the coming months for technical feedback and will then be laid before Parliament. The changes are expected to come into force later this year, subject to parliamentary time.

Ahead of the changes trustees should review their position to check if their trust will fall within the extended scope of registration or data sharing.

How we can help

We can help you assess whether your trust will be affected by the upcoming changes to the TRS rules, and support you with registration and reporting if required. For advice or assistance, please get in touch with your usual Saffery contact or Will Leonard.