The UK’s Trust Registration Service (TRS) has become one of the most far-reaching compliance obligations facing overseas trustees today. What started life as a modest anti-money laundering measure has evolved into a comprehensive transparency regime.
The TRS was introduced in 2017 to implement the EU’s Fourth Anti-Money Laundering Directive, initially applying only to trusts with a UK tax liability.
The scope expanded dramatically in October 2020, when transparency, not just tax collection, became the primary objective.
What Information Must Be Registered?
The TRS requires disclosure of information about the trust and all key parties. For all trusts that need to be registered, you will need:
- The name of the trust and the date it was created
- Whether the trust is an express trust
- The governing law and country of administration
- A description of the trust assets and their approximate value
- Details of the settlor or settlors
- Details of the lead trustee and all other trustees
- Details of all beneficiaries – named beneficiaries individually; classes of beneficiaries by description
- Details of any protectors or other individuals and organisations involved in the trust
For trusts with layered structures the information-gathering exercise can be considerable.
Annual Updates and Ongoing Obligations
Registration is not a one-off exercise. The TRS imposes a continuing obligation to keep the register accurate and up to date.
- Annual declarations are required for trusts with a UK tax liability, confirming the registered information remains accurate
- Event-driven updates must be filed within 90 days of any change of information disclosed.
Trustees should have a system in place to identify triggering events and notify their UK advisers promptly.
The June 2026 Changes: What Is New and Who Is Affected
HMRC’s updated guidance from 30 June 2026 introduced five changes.
1. Non-UK Trusts Holding UK Property
Prior to June 2026, there was some ambiguity in HMRC’s guidance around the precise scope of the registration obligation for non-UK trusts holding UK property indirectly – for example, through an underlying company or a nominee arrangement. That ambiguity has now been resolved, and not in trustees’ favour.
The June 2026 changes confirmed and strengthened the position that any non-UK trust with a beneficial interest in UK land – whether held directly or through an intermediate vehicle – is within scope of the TRS registration obligation. The key points are:
- Indirect holdings are expressly caught – a corporate layer between the trust and the UK property does not remove the obligation
- Nominee and bare trustee arrangements are addressed directly – the beneficial trust, not merely the nominee, must register. A Register of Overseas Entities filing for the nominee company is not sufficient on its own
- No de minimis threshold applies – even a modest UK property interest triggers registration
2. The Low Value Trust Exemption
The June 2026 changes also introduced a low value trust exemption from certain TRS obligations. This is a welcome development, but its scope is narrower than many trustees had hoped. The exemption applies where:
- The trust has no UK tax liability
- No interest in UK land
- No assets of appreciable worth exceeding £2,000
- Cumulative assets not exceeding £10,000 since creation
- Annual gross income not exceeding £5,000
There is also a one-trust-per-settlor limit: only one trust per settlor can rely on the general exclusion.
In practice, the low value trust exemption is likely to be of most relevance to small family trusts with modest offshore assets and no UK connections – rather than the kind of substantial offshore structures. For those structures, the exemption will rarely be available.
3. Extension of the Two-Year Bereavement Exemption
The existing two-year exemption for trusts arising on death has been extended to additional categories of trust that are temporary in nature and arise as part of estate administration. Executors and personal representatives will have greater breathing room, provided the trust is genuinely wound up within the two-year window. If it continues beyond that point, registration will be required.
4. SDRT No Longer Triggers TRS Registration
From 30 June 2026, a liability to Stamp Duty Reserve Tax (SDRT) alone no longer brings a trust within the scope of taxable registrable trusts.
5. Scottish Survivorship Destination Trusts Exempted
A specific exclusion has been introduced for Scottish survivorship destination trusts, removing them from the TRS entirely.
The Consequences of Non-Compliance
The penalty regime may look modest on paper – a written warning for a first failure, £100 for subsequent failures, and up to £5,000 for deliberate non-compliance. But the real risk lies elsewhere.
UK banks, law firms, and estate agents are required to verify TRS registration as part of their anti-money laundering checks. An unregistered trust can find itself unable to open a UK bank account, instruct a solicitor, or complete a property transaction until the position is regularised. And increasingly, HMRC is treating TRS non-compliance not as an end point, but as an opening – a prompt to look more closely at the trust’s wider tax affairs.
How Kingsley Napley Can Help
The TRS landscape has become significantly more complex, and the cost of getting it wrong – practically and reputationally – has never been higher.
Our private client and tax teams advise overseas trustees, international families, and offshore trust companies on all aspects of UK trust compliance. Whether you need to assess your registration obligations for the first time, understand how the June 2026 changes affect your existing structure, or simply make sure your registration is current and complete, we are here to help.
If you are unsure where your trust stands, now is the time to find out.
