Trust Registration Service (TRS) — the complete UK guide for accountants and solicitors
What it is, who must register, what to file, the 90-day clock, exemptions, penalties, and how the TRS interacts with MLR 2017 customer due diligence.
By Mehmood Rajoka · Last updated 2026-06-08
TL;DR — Quick Summary
- •The Trust Registration Service (TRS) is HMRC's central register of UK express trusts under MLR 2017 Regulation 45ZA. Run by HMRC, accessed online via Government Gateway.
- •Almost all UK express trusts must register — regardless of whether they pay tax. The 2020 expansion ('TRS 2.0') brought non-taxable trusts into scope.
- •Registration must include trustees, settlor(s), beneficiaries (or class of beneficiaries), the trust deed, and the trust's UK tax position.
- •Deadline: within 90 days of the trust being created (for new trusts) or 90 days of any material change. Late registration triggers penalties of £100 plus daily charges.
- •Solicitors and accountants involved in trust formation and administration carry the practical compliance burden — and must reconcile TRS records against the firm's own beneficial-ownership findings as part of MLR 2017 CDD.
Answer-first summary
What is the Trust Registration Service?
The Trust Registration Service (TRS) is HMRC's central online register of UK express trusts and certain non-UK trusts with UK connections. It was introduced under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) Regulation 45ZA — implementing the UK's Fifth Anti-Money Laundering Directive obligations on beneficial ownership transparency. The TRS records who created each trust, who runs it, who benefits from it, and what it holds. Since the 2020 expansion (often called 'TRS 2.0'), almost all UK express trusts must register, regardless of whether the trust generates any UK tax liability.
- Run by HMRC, accessed via Government Gateway (agent or lead-trustee credentials)
- Records trustees, settlor(s), beneficiaries (or class), protector (if any), deed, and tax position
- Underpinned by MLR 2017 Reg 45ZA — an AML-driven transparency obligation, not just a tax one
- Largely non-public; shared with law enforcement and (subject to legitimate-interest tests) regulated businesses
Which trusts must register
The default position since the 2020 expansion is: assume every UK express trust must register, then check whether a specific exemption applies. Four broad categories are in scope.
All UK express trusts
Any express trust created under UK law — by deed, will, or written declaration — falls within scope. This includes discretionary trusts, life-interest trusts, accumulation and maintenance trusts, and bare trusts.
Non-UK trusts that acquire UK assets
Non-UK express trusts that acquire UK land or enter into a business relationship with a UK regulated entity must also register. Acquiring a single UK property or opening a UK bank account triggers the obligation.
Trusts with UK tax liabilities
Any trust — UK or non-UK — that incurs UK income tax, capital gains tax, inheritance tax, SDLT, or stamp duty reserve tax must register on the TRS, even if the trust would otherwise be out of scope.
Some employment-related and pension trusts
Most occupational pension schemes are exempt, but certain employment-related share schemes and discretionary employee benefit trusts are in scope. Check the specific trust type against HMRC's TRS guidance.
Exempt trusts
The exemptions are narrow and specific. If a trust doesn't clearly fall into one of these categories, register it — the cost of unnecessary registration is small; the cost of missing a registration is a £100 penalty plus continuing daily charges.
- Trusts imposed by statute or by court order (e.g. trusts of land arising under the Trusts of Land and Appointment of Trustees Act 1996)
- Most registered UK pension schemes (HMRC-registered occupational and personal pension schemes)
- Charitable trusts registered with the Charity Commission
- Pilot trusts created before 6 October 2020 holding under £100 (with conditions)
- Will trusts that come to an end within 2 years of death
- Insurance policy trusts that pay out only on death or critical illness
- Co-ownership trusts of property where the trustees and beneficiaries are the same persons
What information you need to register
HMRC requires identity details for every party with a stake in the trust, plus the trust's constitutive documents and tax position. Have the paperwork ready before starting the Government Gateway session — it will time out if you pause too long.
All trustees
Names, dates of birth, nationality, country of residence, National Insurance numbers (where UK resident), and passport details (where non-UK).
Settlor(s)
The same identity details as for trustees, plus the date the trust was created. For a will trust, the settlor is the deceased.
Beneficiaries — named or as a class
Named beneficiaries require full identity details. For discretionary trusts with a class of beneficiaries (e.g. 'the settlor's descendants'), describe the class — individual identification is required only when a beneficiary receives a benefit.
Trust details
The trust deed (or written declaration), the date of creation, the governing law, the principal assets, and the trust's tax position.
Protector (if any)
If the trust has a protector or any person with comparable powers to remove or appoint trustees, their identity details must be recorded.
Material changes — within 90 days
Any change in trustees, settlor, beneficiaries, the principal assets, or the trust's tax position must be updated on the TRS within 90 days of the change.
Deadlines and the 90-day clock
All trigger-based deadlines are 90 days. The clock runs from the trigger event itself — not from when the trustees realise the obligation has arisen.
Penalties for non-compliance
HMRC has a graduated penalty regime, with separate exposure under MLR 2017 enforcement and via the SRA or professional body. The penalty for missing a single registration is modest; the cumulative cost across a portfolio of trusts adds up quickly.
Late registration
First offence: £100 fixed penalty. Continued failure: daily penalties of up to £60 a day. Deliberate or repeated failure can attract higher penalties under Finance Act 2008 Schedule 41.
Late or missing material-change update
Same £100 fixed penalty + daily charges as for late initial registration. HMRC treats updates as continuing obligations once the trust is on the register.
Inaccurate registration
Penalties under FA 2007 Schedule 24 for inaccuracies — graduated by whether the error was careless, deliberate, or deliberate-and-concealed.
Knock-on AML and SRA / professional-body exposure
Solicitors and accountants who fail to ensure the trusts they act on are properly TRS-registered face supervisory action separately from the HMRC penalty regime.
Practitioner's checklist
How to handle TRS work inside a UK accountancy or solicitors' practice, end-to-end:
- 1Confirm at instruction whether the trust is registrable (use HMRC's TRS guidance checklist)
- 2Identify the trustees, settlor(s), beneficiaries, and protector at the outset — same identity standards as MLR 2017 CDD
- 3Capture the trust deed or written declaration before registration begins
- 4Calculate the 90-day clock from the creation date (or material-change date)
- 5Register via the Government Gateway with the firm's agent credentials
- 6Cross-check the TRS record against your firm's independent beneficial-ownership findings — log any reconciliation differences
- 7Record the TRS reference number and certificate on the file
- 8Diarise material-change reviews — at least annually for active trusts, more often for trusts with frequent distributions
- 9Build TRS status into your firm-wide AML risk assessment for trust work
FAQ
Answer-first summary
Does every UK trust need to register on the TRS?
Almost all UK express trusts must register, including non-taxable ones since the 2020 expansion. Limited exemptions exist for charitable trusts registered with the Charity Commission, most HMRC-registered pension schemes, certain insurance policy trusts, statutory trusts, and pilot trusts created before 6 October 2020 holding under £100. If you're unsure, the default position is to register — the cost of unnecessary registration is small; the cost of missing one is a £100 penalty plus daily charges.
Answer-first summary
What is the deadline for registering a new trust?
Within 90 days of the trust being created. For trusts created before 1 September 2022 that fell into scope under the 2020 expansion, the deadline was 1 September 2022 — those are now overdue if not registered. Any material change to an existing registration must be updated within 90 days of the change.
Answer-first summary
What's the difference between a registrable express trust and a bare trust?
A bare trust (where the beneficiary has an immediate and absolute right to both income and capital) is still an express trust for TRS purposes and is in scope. The bare trust label affects tax treatment but not the registration obligation — unless an exemption applies, register it.
Answer-first summary
Who can register a trust on the TRS?
The lead trustee, an authorised agent acting for the trust, or a solicitor or accountant with agent access via Government Gateway. Most professional trust administrators register on behalf of the trustees as part of the formation work. The lead trustee remains legally responsible regardless of who carries out the registration.
Answer-first summary
What information do I need to register a trust?
Identity details for trustees, settlor(s), and beneficiaries (or beneficial class), the trust deed or written declaration, the date of creation, governing law, principal assets, the trust's tax position, and (where applicable) protector details. Have the documents ready before starting — Government Gateway times out if the session is paused too long.
Answer-first summary
Is the TRS public?
Largely no — TRS data is not on a public register the way Companies House PSC information is. HMRC will share TRS data with law enforcement and, on request and subject to a 'legitimate interest' test, with regulated businesses for AML purposes. Beneficiaries of a trust can request access to the TRS record for trusts they benefit from.
Answer-first summary
How does TRS interact with MLR 2017 CDD obligations?
TRS registration is a separate HMRC obligation from MLR 2017 CDD — but they overlap. When acting on a trust as a regulated business, you still owe full CDD on the trustees, settlor, and beneficiaries under MLR 2017 Regulation 28. TRS data is a useful CDD source but should be cross-checked against independent evidence; relying on TRS alone does not discharge the CDD obligation.
Related glossary and guides
Trust Registration Service
The canonical definition + 90-second summary
Express trust
Distinguished from implied and constructive trusts
Beneficial owner
Identifying the people behind a trust for CDD
Customer Due Diligence (CDD)
MLR 2017 Reg 28 obligations for trust clients
Register of Overseas Entities (ROE)
Companion register for overseas entities owning UK property