New TRS Regulations Now Implemented: Key Pointers for Trustees

HMRC has implemented significant amendments to the Trust Registration Service (TRS) effective from 30 June 2026, aimed at enhancing transparency whilst minimising administrative burden for lower-risk trusts. These modifications impact both UK and non-UK trustees and may alter the requirement to register or update trust information on the TRS.

A notable change involves the expanded registration obligations for certain non-UK trusts holding UK land or property. Even in cases where no UK tax liability arises, non-UK trusts that acquired UK property prior to 6 October 2020 and continue to hold it may now be required to register, with a transitional deadline set for 1 September 2027. HMRC has also introduced a new de minimis exemption for low-value, low-risk trusts, removing the need to register where the trust’s assets fall below specified thresholds, including UK property ownership, asset value (£10,000), annual income (£5,000), and significant non-financial assets (£2,000). Additionally, the two-year registration exemption for trusts that arise on death has been extended, reducing administrative demands during estate administration.

Furthermore, HMRC has revised the TRS information sharing protocols, permitting certain organisations with a legitimate interest in preventing financial crime to request trust information under specific circumstances. While trust data remains non-public, trustees should be aware that information submitted to HMRC may be shared where legally permitted. Trustees are advised to review their current arrangements to determine whether registration is now required, whether an exemption applies, or whether existing TRS entries require updating particularly for trusts holding non-UK property, trusts established on death, and trusts potentially covered by the new de minimis exemption.