Trust Registration Service UK: What It Is, Who Must Register, and How to Do It (2026)

The Trust Registration Service (TRS) is HMRC's online register for UK trusts. Since 1 September 2022, almost all express trusts — including family discretionary trusts, bare trusts, and life interest trusts — must be registered on the TRS, whether or not they have a tax liability. Trusts created on or after 6 October 2020 must register within 90 days of creation. Failure to register can result in financial penalties from HMRC, starting at a fixed £100 and rising to £5,000 or 5% of trust assets for deliberate non-compliance.

What Is the Trust Registration Service?

The Trust Registration Service was created in 2017 to comply with the EU's Fourth Money Laundering Directive (4MLD), which required HMRC to maintain a register of trusts with UK tax liabilities. At that stage, only taxable trusts — those paying income tax, capital gains tax, or inheritance tax — needed to register.

In 2022, the scope expanded dramatically. The implementation of the Fifth Money Laundering Directive (5MLD) brought almost all express trusts within scope, regardless of whether the trust had any tax obligations at all. The new requirement came into force on 1 September 2022, and the deadline for existing trusts to register passed on that date.

This is the change that catches many families by surprise. You do not need to owe HMRC any money for your trust to require registration. If a trust exists — if someone has deliberately created a legal arrangement placing assets under the control of trustees for the benefit of beneficiaries — that trust almost certainly needs to be on the register.

The TRS is not a public database. It is a compliance register held by HMRC. Third parties such as legal advisers and AML-regulated businesses can request access under certain circumstances, but it is not searchable by the general public. The register exists for anti-money-laundering purposes, not to expose your family's financial arrangements.

Which Trusts Must Register?

Since 1 September 2022, almost all express trusts must register with HMRC's TRS — regardless of whether they have a UK tax liability. An express trust is one created deliberately by a settlor, as opposed to trusts that arise by operation of law such as constructive trusts.

The following types of trust must register:

• Family discretionary trusts — including trusts set up to protect assets, plan for inheritance tax, or manage wealth across generations
• Bare trusts — where the beneficiary has an immediate and absolute right to both the capital and income of the trust
• Life interest trusts (interest in possession trusts) — where a beneficiary has the right to receive income from the trust during their lifetime
• Accumulation trusts — where income is accumulated within the trust rather than distributed
• Mixed trusts — trusts that combine elements of more than one type
• Certain trusts holding life insurance policies — where the policy is held outside the estate and the trust has wider purposes beyond a straightforward death benefit

If you have completed setting up a family trust in the UK, the probability that it requires TRS registration is high — even if it has never been taxed, never received income, and was set up primarily for asset protection rather than tax planning.

The scope is deliberately broad. HMRC's position is that registration is required as a default. The burden is on trustees to establish that their trust falls within an exemption — not the other way around.

Which Trusts Are Exempt?

Certain categories of trust are excluded from the TRS registration requirement. The main exemptions are:

• Charitable trusts — registered with the Charity Commission or equivalent
• Statutory trusts — trusts created by legislation, such as those that arise when someone dies without a will (intestate)
• Pilot trusts — very limited trusts created before 6 October 2020 with assets of £100 or less, provided no further assets have been added
• Co-ownership trusts — trusts that hold land where the legal owners and beneficial owners are identical
• Registered pension schemes — regulated pension trusts
• Certain life policy trusts — where the sole purpose is to pay out on death, terminal illness, or critical illness of the insured, and nothing else is held
• Child Trust Funds and Junior ISAs
• Will trusts wound up within two years — trusts created by a will that are fully administered and closed within two years of the date of death (longer-running will trusts must register once they pass the two-year mark)

If your trust does not fall clearly into one of these categories, it must be registered.

What Information Is Needed to Register?

Before you sit down at the TRS portal, gather the following:

About the trust:

• The full trust name (as stated in your Trust Deed)
• Date the trust was created
• The governing law of the trust (usually England & Wales or Scotland)
• A brief description of the assets held and their approximate value

About the settlor(s):

• Full name, date of birth, address, and National Insurance number (or passport details)

About the trustees:

• Full name, date of birth, address, and National Insurance number for each trustee
• If any trustee is a company: company name, UTR, and registered address

About the beneficiaries:

• For discretionary trusts with a class of beneficiaries, a description of the class is sufficient (e.g. "the children and remoter issue of [settlor name]")
• Where specific named beneficiaries have a fixed interest: full name, date of birth, and NI number or passport details

This is exactly why having a professionally prepared family discretionary trust deed is so important before you register. The TRS asks for the trust name, the creation date, the governing law — all of which are stated explicitly in a well-drafted Trust Deed. Without that document to hand, registration becomes guesswork.

How to Register — Step by Step

Registration is completed via HMRC's online TRS portal at gov.uk. Here is how to work through it:

Step 1 — Create a Government Gateway account

If you do not already have one, go to gov.uk and create a Government Gateway account. You will need an email address and some personal identification to verify your identity.

Step 2 — Access the TRS portal

From your Government Gateway dashboard, navigate to "Trust Registration Service" and select "Register a new trust."

Step 3 — Enter trust details

You will be asked for the trust name, the type of trust, the date it was created, and the governing law. Keep your Trust Deed in front of you throughout this section.

Step 4 — Add settlor, trustee, and beneficiary information

Work through the online form to add details for each party. For discretionary trusts, you can describe the class of beneficiaries rather than listing every potential beneficiary by name — which is important given that a well-drafted trust will name a broad class that could include future grandchildren not yet born.

Step 5 — Describe the trust assets

Provide a brief description of the assets placed in trust and their approximate current value. Precision is not required at this stage, but accuracy matters.

Step 6 — Submit and receive your Unique Reference Number

Once submitted, HMRC will issue a Unique Reference Number (URN) for the trust. This is your proof of registration. Keep it securely alongside your Trust Deed — you will need it for future HMRC correspondence and for any tax filings that relate to the trust.

Keeping the register up to date

TRS registration is not a one-time event. Any change to the trust — a new trustee appointed, a beneficiary added or removed, a change in the trust assets, a trustee's address updated — must be reported to HMRC via the TRS portal within 90 days of the change occurring. Ongoing compliance is part of responsible trust administration.

What Happens If You Don't Register?

The consequences of failing to register — or of failing to keep the registration current — are real and escalating.

HMRC's penalty regime for TRS non-compliance:

• First offence (late registration): A fixed penalty of £100
• Second offence: A further fixed penalty of £200
• Deliberate non-compliance: Where HMRC determines the failure was intentional, the penalty can rise to up to £5,000 or 5% of the trust assets — whichever is higher

HMRC took a measured approach to enforcement in the months immediately following the September 2022 deadline, recognising that many trustees were unaware of the expanded requirement. That initial grace period has passed. As the rules are now well-established, the expectation of compliance is harder to dispute.

Beyond HMRC penalties, unregistered trusts create practical problems. Legal advisers, accountants, and financial institutions increasingly require TRS registration evidence as standard. Without a URN, your trust may face difficulties opening bank accounts, dealing with professional advisers, or completing certain asset transactions. An unregistered trust is also far more exposed in any compliance investigation or dispute.

Starting with solid trust documents makes registration straightforward.

The Family Protection Pack includes a Family Discretionary Trust Deed, Letter of Wishes, and Nominee Declaration — everything you need before you register with HMRC's TRS.

Protect Your Legacy →

Do You Need a Solicitor to Register?

No. Registration on the TRS portal is a process any trustee can complete directly, using a Government Gateway account. HMRC designed it to be self-service, and the portal guides you through each section step by step.

That said, two situations benefit from professional input before or during registration.

When the trust documents are incomplete or unclear. The TRS asks specific questions about the trust name, type, creation date, and beneficiary structure. If your Trust Deed does not clearly answer these questions — or if you do not have a properly drafted Trust Deed — registration is harder to complete accurately and you risk providing incorrect information to HMRC.

When the trust has complex tax implications. If your trust has taxable income or gains, holds high-value property, or if there is any uncertainty about its IHT position, a tax adviser or solicitor familiar with trust compliance should be involved. The TRS registration itself is straightforward; the tax obligations that may flow from it are a separate matter that deserves specialist attention.

For families who have a clear, professionally prepared Trust Deed and a straightforward structure, registration is entirely manageable without a solicitor. The key is to have the right document in front of you when you sit down to start.

Frequently Asked Questions

Do I have to register a family discretionary trust with HMRC?

Yes — since 1 September 2022, all express trusts (including family discretionary trusts) must be registered on the TRS unless specifically exempt. This applies whether or not the trust has any UK tax liability.

What is the deadline to register a trust on TRS?

Trusts created before 6 October 2020 had to register by 1 September 2022. New trusts created on or after 6 October 2020 must register within 90 days of creation.

Is there a fee to register a trust on TRS?

No — registration on HMRC's Trust Registration Service is free.

What happens if I don't register my trust?

HMRC can issue a fixed £100 penalty for late registration. Deliberate non-compliance can attract a penalty of up to £5,000 or 5% of the trust assets, whichever is higher.

Can I register a trust myself without a solicitor?

Yes — you can register directly on HMRC's TRS portal using a Government Gateway account. Having your trust deed to hand makes the process much faster and more accurate.

What details do I need to register a trust?

You'll need the trust name, date of creation, governing law, and details of the settlor(s), trustee(s), and beneficiaries — including full name, date of birth, and National Insurance number or passport number for each individual.

Get your trust documents right before you register — the Family Protection Pack gives you everything you need.

Protect Your Legacy →

This guide is for informational purposes only and does not constitute legal or tax advice. Heirs & Order™ is not a law firm. We recommend consulting a qualified solicitor or tax adviser before making any decisions about trust registration.