Following new regulations which came into effect on 16 July 2025, certain trusts are now required to register with HMRC’s AEOI Service. The official deadline for registration was 31 December 2025 or 31 January following the calendar year in which the entity first falls within the definition of Reporting Financial Institution, however HMRC have confirmed that penalties will not automatically be issued for late registration if reasonable efforts have been made to comply.

AEOI registration is a one-off obligation. Once registered, an entity will remain on the register until it deregisters.

For those who have already registered on the TRS (Trust Registration Service), this may seem like unnecessary bureaucracy, but this particular system is established so that HMRC can exchange information internationally, therefore its purpose, and the details that it wishes to gather are slightly different. The aim of both the CRS and FATCA is to ensure that tax evasion can be minimised on an international level.

AEOI obligations stem from the recent ‘International Tax Compliance (Amendment) Regulations 2025’ which were enacted to create a database on UK entities sufficient to comply with CRS (Common Reporting Standards) as agreed between the OECD countries, and US FATCA (Foreign Account Tax Compliance Act) regulations.

It is not anticipated that these new regulations will impact the UK exchequer to any meaningful extent. The cost of compliance with the new rules is estimated to be £107m across all businesses, trusts and organisations in the UK, but this is anticipated to be a one-off cost. The cost to HMRC of implementing the systems to monitor this information is estimated at £27m.

To save charitable institutions unnecessary expense they have been excluded from having to comply with these regulations.

Trusts required to register with the AEOI service

There are many types of trusts which may be required to register on the AEOI platform. The vast majority of these will be Managed Investment Entities, however we have considered below some other types of trusts which will require to register.

Managed Investment Entities:

Trusts which meet two tests are considered to be Managed Investment Entities and must register on AEOI. These are the management test and the assets test.

  • If the trustees of your trust include a financial institution or your financial assets are being professionally managed then the ‘management’ test is met. It should be noted that a corporate trustee associated with a law firm or accountancy firm will usually be considered a financial institution for these purposes.
  • If more than 50% of the income of the trust is attributable to investing, reinvesting or trading in financial assets in the prior three years (or since inception if less) then the ‘assets’ test is met.

Custodial institutions:

Within our client portfolio, this type of trust will be uncommon. These trusts will have over 20% of their income arising from fees and commissions associated with holding and investing financial assets on behalf of others. From a practical perspective Employee Benefit Trusts may fall into this category.

Activity-based Investment Entities:

Again, this type of trust will be very rare within our client base but encompasses trusts which generate more than 50% of their income from fees and commissions associated with holding and investing financial assets on behalf of others.

If you need any assistance with registration, or advice on whether or not your trust is obliged to register please get in contact with our personal tax team.