Automatic Exchange of Information (AEOI) mandatory registration for Trusts

HMRC has recently introduced a mandatory registration for Trusts for Automatic Exchange of Information (AEOI), which is in addition to the existing HMRC Trust Register.

Until now, most trusts have fallen outside the scope of AEOI.  Only trusts that made distributions to beneficiaries living in a reportable jurisdiction had reporting obligations; other trusts were not required to file AEOI returns or register for the service.

The new regulations require all financial institutions to register with HMRC via their AEOI service to comply with UK international tax compliance regulations, even if no reporting is required.  These changes have not been well publicised by HMRC, and guidance has only been published last week by HMRC and professional bodies.

For trusts affected by these changes, registration is mandatory. HMRC has set a deadline of 31 December 2025, with possible penalties for late registration.

Who is affected?

Any trust classified as a financial institution under the Common Reporting Standard (CRS) will be required to register for AEOI.  In broad terms this usually applies where:

• The trust runs a business in the UK and more than half of its income comes from activities such as trading in financial instruments, portfolio management or the managing investment funds; or
• More than half of the trust’s income comes from investing or trading in financial assets, and the trust or its assets are managed by a UK based business that carries out those activities.

In practice, this means that most trusts which hold discretionary managed investment portfolios will now need to register and report under AEOI. Trusts that hold property, loans or life insurance policies do not currently need to register.

The rules apply to trusts with corporate trustees (such as Cripps Trust Corporation Limited) and those with individual trustees.

Family Investment Companies and Partnerships may also be affected if their income comes from investments managed on a discretionary basis.

There are some exceptions.  For example, no action is needed if the trust is already registered for AEOI.  Charities, registered pension schemes and trusts holding only offshore bonds do not currently need to register.  Trusts which hold land, property or loans are outside the scope for now, but this should be reviewed, particularly if the assets change.

If you are unsure whether your trust is affected by the new AEOI requirements, please get in touch and we can advise further.

What next?

Trusts that need to register must do so by 31 December 2025, or 31 January following the calendar year in which the obligation arises.  HMRC can apply penalties for late registration or late AEOI reporting.

Registration is a one-off process. Once completed, the trust remains compliant until it de-registers.

Ongoing reporting may be required if payments are made to beneficiaries in reportable jurisdictions.  The reporting period follows the calendar year and AEOI returns must be filed no later than 31 May the following year.  Our team can assist with those.

If there are no reportable distributions, trustees do not need to file a nil return.

How can we help?

Our trust team is highly experienced in all aspects of trust tax compliance and can assist with AEOI registrations ahead of the 31 December 2025 deadline.

For trusts that are currently under our management (or where Cripps Trust Corporation Limited is appointed as a trustee) we will deal with registration on behalf of the trustees.  There will be a one-off fee of £250 plus VAT per registration.

For all other trusts, we can review your trust assets, advise on your reporting obligations and complete the registration on for you.  Our fee for this comprehensive service is £750 plus VAT.

Further information

If you would like any further information on AEOI or advice on trusts generally, please contact your Cripps relationship manager or our trust team on [email protected] who will be happy to assist.