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Trusts

Trust Registration Service: What Trustees Must Do

Most express trusts in the UK must be registered with HMRC, and it is usually the trustees who are responsible for doing it and keeping the record current.

9 min read · Written by the Fairchild Oldfield team · Last reviewed: July 2026

90 days
The window trustees generally have to register a new trust, and to report later changes, on the Trust Registration Service once the trust is set up or the change happens.
Source: gov.uk, as at July 2026, subject to change.

The Trust Registration Service is HMRC's online register of trusts, set up to meet anti-money laundering rules. Most UK express trusts must be recorded on it, whether or not the trust pays any tax, and the trustees are usually the ones responsible for registering and keeping the details accurate.

If you have been appointed a trustee, registration is one of the first duties to deal with, and missing it can lead to a penalty. This guide explains which trusts need to register, which are left out, the deadlines, and what keeping the register up to date involves. It sits alongside our Trusts Explained guide and our note on trustee duties. Figures are current as at July 2026 and are subject to change.

What is the Trust Registration Service?

The Trust Registration Service, often shortened to TRS, is the online register HMRC uses to record UK trusts. It was introduced to meet money laundering regulations and holds details of the settlor, trustees, beneficiaries and assets. Registration is generally the trustees' responsibility, and it applies to many trusts that pay no tax at all, not only those with a tax bill (gov.uk, register a trust as a trustee, as at July 2026, subject to change).

Which trusts must be registered?

Broadly, most UK express trusts must register, alongside any trust that has a UK tax liability. An express trust is one deliberately created by a settlor, usually in writing, rather than one imposed by law. Taxable trusts must register where they are liable to a UK tax, and many non-taxable express trusts must also register unless they fall within a specific exclusion (gov.uk, check if you need to register a trust, as at July 2026, subject to change).

Trust typeRegister?
Taxable trust (liable to Income Tax, CGT, IHT, SDLT and similar)Yes, where a UK tax liability arises
UK express trust with no tax liabilityGenerally yes, unless excluded
Non-UK express trust with certain UK linksSometimes, depending on the link
Trust that falls within a Schedule 3A exclusionNot unless it becomes liable to UK tax

Source: gov.uk, check if you need to register a trust, as at July 2026, subject to change.

The exceptions

Trusts that do not need to register

Certain trusts are left out of the registration requirement, at least while they have no UK tax liability. These exclusions are set out in Schedule 3A and cover many everyday arrangements, so not every trust you come across needs to be recorded. If any of these excluded trusts later becomes liable to a UK tax, the exclusion generally falls away and registration is then required (gov.uk, check if you need to register a trust, as at July 2026, subject to change).

Commonly excluded arrangements include a will trust wound up within two years of the death, trusts holding only a life or retirement policy paying out on death or illness, most jointly owned property held as tenants in common, registered UK charity trusts, and certain pension scheme trusts (gov.uk, as at July 2026, subject to change). The full list is more detailed, so it can be worth checking each case rather than assuming.

The penalty for not registering

£5,000

HMRC states that a trustee who fails to register a trust that should be on the register may need to pay a penalty of up to this amount, so registration is a duty worth taking seriously (gov.uk, as at July 2026, subject to change).

Trust Registration Service deadlines

The main deadline for a new trust is 90 days. A trust created after 6 October 2020 must generally be registered within 90 days of being set up, or of it becoming liable for tax, whichever gives the later date (gov.uk, register a trust as a trustee, as at July 2026, subject to change). Older trusts and taxable trusts can have different cut-off dates, so the timing depends on when the trust arose and why it needs to register.

SituationDeadline
New trust created after 6 October 2020Within 90 days of creation, or of becoming liable to tax, whichever is later
Reporting a later change to the trustWithin 90 days of the change
Taxable trust annual confirmationBy 31 January in the tax year after the liability arises

Source: gov.uk, register a trust as a trustee and gov.uk, manage your trust's details, as at July 2026, subject to change.

A worked example (illustration only). A parent dies and their will sets up a discretionary trust for grandchildren that the trustees expect to run for many years. Because it is an ongoing express trust rather than one wound up within two years, the trustees generally need to register it on the Trust Registration Service within 90 days of the trust being set up (gov.uk, as at July 2026, subject to change). If a trustee later retires and a new one is appointed, that change would generally need reporting within 90 days too (gov.uk, as at July 2026, subject to change). Every trust is different, and whether an exclusion applies can change the answer, so this is general information rather than advice on a specific trust.

Keeping the register up to date

Registration is not a one-off task. Trustees generally need to tell HMRC about changes to the trust, such as new trustees, a change of beneficiaries or updated details, within 90 days of the change happening (gov.uk, manage your trust's details, as at July 2026, subject to change). Where the trust is liable to Income Tax or Capital Gains Tax, the trustees also confirm each year, by 31 January, that the register is up to date or that nothing has changed (gov.uk, as at July 2026, subject to change).

  • New or retiring trustees. Appointments and retirements generally need reporting within 90 days. Source: gov.uk, as at July 2026, subject to change.
  • Changes to beneficiaries. Additions or removals should be kept current on the register.
  • Annual confirmation. Taxable trusts confirm the position each year by 31 January. Source: gov.uk, as at July 2026, subject to change.

How it works in practice

Registering as a trustee

I

Check the position

Confirm whether the trust needs to register or falls within an exclusion.

II

Gather the details

Collect information on the settlor, trustees, beneficiaries and assets.

III

Register online

Set up a Government Gateway account and register within the deadline. Source: gov.uk, as at July 2026, subject to change.

IV

Keep it current

Report changes within 90 days and, for taxable trusts, confirm yearly. Source: gov.uk, as at July 2026, subject to change.

The register across Scotland and Northern Ireland

The Trust Registration Service is run by HMRC and applies across the whole of the UK, so trustees in Scotland and Northern Ireland use the same register and the same deadlines as those in England and Wales (gov.uk, register a trust as a trustee, as at July 2026, subject to change). What differs is the surrounding trust and succession law. Scotland has its own rules on trusts and on how estates are dealt with, and Northern Ireland has a separate system that is broadly similar to England and Wales. Where a trust touches more than one UK nation, it can be worth taking advice in each. For the wider picture, see our estate planning guide.

Frequently asked questions

What is the Trust Registration Service?

It is HMRC's online register of trusts, introduced to meet anti-money laundering rules. It records details such as the settlor, trustees, beneficiaries and assets. Most UK express trusts must be listed on it, whether or not they pay tax, and registering and updating it is generally the trustees' responsibility (gov.uk, as at July 2026, subject to change).

Which trusts have to register?

Broadly, taxable trusts with a UK tax liability and most UK express trusts must register, unless a specific exclusion applies. An express trust is one deliberately created by a settlor rather than imposed by law. Some non-UK trusts with UK links also register. Because the rules are detailed, many trustees check the position on gov.uk or with a professional (gov.uk, as at July 2026, subject to change).

What is the deadline to register a trust?

A trust created after 6 October 2020 must generally be registered within 90 days of being set up, or of becoming liable to tax, whichever is later. Later changes to the trust also generally need reporting within 90 days (gov.uk, as at July 2026, subject to change). Different dates can apply to older or taxable trusts, so the timing depends on the trust.

What happens if a trust is not registered?

HMRC can charge a penalty of up to £5,000 where a trustee fails to register a trust that should be on the register (gov.uk, as at July 2026, subject to change). Because registration is an anti-money laundering duty, it is generally treated seriously. If you are unsure whether a trust should have registered, it can be worth taking advice promptly.

Do trustees have to update the register?

Yes. Trustees generally report changes, such as new or retiring trustees or a change of beneficiaries, within 90 days of the change. Where the trust is liable to Income Tax or Capital Gains Tax, the trustees also confirm each year by 31 January that the register is up to date (gov.uk, as at July 2026, subject to change). Non-taxable trusts do not make the annual confirmation.

Does a will trust need to be registered?

It depends on how long it lasts. A trust created by a will and wound up within two years of the death is often excluded from registration, but a will trust that carries on beyond that generally needs to register as an ongoing express trust (gov.uk, as at July 2026, subject to change). Because the two-year point matters, many trustees check the position before it is reached.

About Fairchild Oldfield

The Fairchild Oldfield team brings together estate planning, tax, independent financial advice and client care, working with families across England and Wales.

Fairchild Oldfield are estate planning specialists and will writers, not a firm of solicitors. This article is general information based on practical experience, not legal, tax or financial advice.

Important: This article is general information only and is not legal, tax or financial advice. Reading it does not create a professional relationship. It is based on the law of England and Wales, and other UK jurisdictions may differ. Figures and rules are current as at July 2026 and are subject to change. Before acting, many people choose to seek advice from a suitably qualified professional, such as a solicitor, a STEP practitioner, an accountant, or an FCA-authorised financial adviser, who can consider your individual circumstances.

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