Expansion of the UK Trust Registration Service: Implications for Non-UK Trusts

The UK will significantly expand the scope of its Trust Registration Service (TRS) from early 2026, bringing many more non UK trusts into the regime. Non UK trusts that acquired UK land or property before 6 October 2020 will now need to register if they still hold it, and all TRS registered non UK trusts will become subject to wider disclosure rules, including legitimate interest and third country entity requests, regardless of trustee residency. The removal of Stamp Duty Reserve Tax as a registration trigger slightly narrows the rules, but only on a non retrospective basis. Existing triggers post 2020 UK property acquisitions, UK tax exposure, and ongoing relationships with UK “relevant persons” remain unchanged, with limited exemptions available for vulnerable beneficial owners.

Trustees should review any UK property holdings ahead of implementation, assess potential UK tax exposure (including through nominee or corporate structures), and ensure beneficial ownership information is accurate and up to date. They may also need to consider disclosure exemption applications, monitor UK professional relationships that could trigger registration, and prepare for timely compliance, as newly registrable trusts will have only six months to register once the new rules take effect