Definition
The Trust Registration Service (TRS) is HMRC's online register where trustees must record details about most UK trusts to comply with anti-money laundering regulations and tax reporting requirements.
Understanding TRS is essential for anyone creating a trust in their will or serving as a trustee, as registration is a legal obligation with potential penalties for non-compliance.
What Does Trust Registration Service Mean?
The Trust Registration Service launched in 2017 for trusts with UK tax liabilities. In October 2020, the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 expanded requirements to cover most UK express trusts—those deliberately created by written document—regardless of tax status. TRS now serves dual purposes: issuing Unique Taxpayer References for taxable trusts and maintaining beneficial ownership records to combat money laundering. Trustees register details about the trust's settlor, beneficiaries, and assets through HMRC's online portal.
Trusts with UK tax liabilities must register within 90 days of becoming liable. UK express trusts created after 6 October 2020 also require registration within 90 days unless specifically exempted. Will trusts receive special treatment—they're exempt for the first two years after death if they only hold estate assets and have no immediate tax liability. Sarah dies leaving her £320,000 home in trust for husband David with remainder to children. Trustees don't need immediate registration but must register before the second anniversary if assets remain in trust. Once registered, trustees must report changes within 90 days and submit annual declarations by 31 January for taxable trusts.
Major exemptions include UK pension schemes, registered charities, statutory trusts from intestacy, will trusts within two years, certain life insurance trusts, and pilot trusts under £100. However, any trust with UK tax liability must register even if otherwise exempt. HMRC can impose penalties up to £5,000 per offence for non-registration or failure to maintain records. Trustees are personally liable—penalties cannot be paid from trust assets. First-time offences typically aren't penalised unless HMRC suspects deliberate non-compliance.
Common Questions
"Do I need to register a trust created in my will with HMRC?" Will trusts are exempt for the first two years after death if they only hold estate assets. After two years, or if the trust has UK tax liability sooner, trustees must register within 90 days.
"What happens if I don't register my trust with the TRS on time?" HMRC can impose penalties up to £5,000 per offence. Trustees are personally liable—penalties cannot be paid from trust assets. First-time offences typically aren't penalised unless HMRC suspects deliberate non-compliance.
"Which trusts are exempt from TRS registration?" Exempt trusts include UK pension schemes, registered charities, statutory trusts from intestacy, will trusts within two years, certain life insurance trusts, and pilot trusts holding £100 or less. Any trust with UK tax liability must register regardless of exemption status.
Common Misconceptions
Myth: All trusts must be registered with HMRC's Trust Registration Service
Reality: Many trusts are exempt, including UK pension trusts, registered charities, statutory trusts from intestacy, and will trusts within two years. However, any trust with UK tax liability must register even if otherwise exempt.
Myth: The Trust Registration Service is only for trusts that pay tax
Reality: Since October 2020, TRS covers most UK express trusts regardless of tax liability as part of anti-money laundering measures. Non-taxable express trusts must register unless they fall within specific exemptions like charitable trusts or will trusts in their first two years.
Related Terms
Understanding Trust Registration Service connects to these related concepts:
- Trust: The legal structure that TRS registers—most UK express trusts require registration as an ongoing administrative obligation
- Trustee: The person legally responsible for registering with TRS and maintaining accurate records within required deadlines
- HMRC: The regulatory body that administers TRS alongside other trust taxation and compliance systems
- Tax Compliance: TRS registration forms one element of broader trust tax compliance, separate from but connected to trust tax returns
- Trust Administration: TRS registration, annual updates, and change reporting are routine administrative tasks in ongoing trust management
Related Articles
- Using Trusts to Protect Your Estate: A Complete Guide for UK Wealth Builders
- Setting Up a Trust for Your Children in Your Will
- Wills for Blended Families: A Complete Guide
- How to Leave Money to a Minor in a Will (UK Guide 2025)
- What Is a Trust? (And How Do They Work in Wills?)
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Legal Disclaimer:
This article provides general information only and does not constitute legal or financial advice. WUHLD is not a law firm and does not provide legal advice. Laws and guidance change and their application depends on your circumstances. For advice about your situation, consult a qualified solicitor or regulated professional. Unless stated otherwise, information relates to England and Wales.