New AEOI Trust Registration Requirement – What Trustees Need to Know
Trustees should be aware of a significant change to international tax compliance obligations in the UK. The International Tax Compliance (Amendment) Regulations 2025 introduced a new mandatory registration requirement with HMRC’s Automatic Exchange of Information (AEOI) service for certain trusts.
Historically, trusts only needed to register for AEOI where they had non-UK connections. Under the new rules, all entities classed as a Reporting Financial Institution or a Trustee-Documented Trust must register with HMRC’s AEOI service.
A trust will typically fall within the scope if it qualifies as a financial institution for the purposes of the Common Reporting Standard (CRS) or the Foreign Account Tax Compliance Act (FATCA), for example where more than 50% of its income arises from financial assets and it is managed by a discretionary investment manager or has a corporate trustee.
The deadline for existing trusts was 31 December 2025, or 31 January following the calendar year in which a trust first falls within scope. Registration is a one-off requirement.
HMRC can impose penalties for late registration (£1,000 plus daily fines), although it has indicated it may not automatically charge penalties where trustees have made reasonable efforts to comply.
This new AEOI obligation is separate from the Trust Registration Service (TRS).
Trustees should review whether their trust meets the criteria and, if uncertain, seek legal advice.
For more information on how Mogers Drewett can help with the AEOI requirements, please do not hesitate to contact Emma Coate – Senior Associate, using the details below.
