HMRC AEOI Registration – Trusts and Entity Structures
HMRC has recently updated its requirements under the Automatic Exchange of Information (AEOI) regime, through which information is exchanged with overseas tax authorities under the Common Reporting Standard (CRS) and, where applicable, with the US Internal Revenue Service under FATCA.
Certain trusts and entity structures may now be required to be registered directly with HMRC if they are classified as Financial Institutions for AEOI purposes, even where reporting has historically been undertaken on their behalf by a third party. This is a one-time registration requirement, with a deadline of 31 December 2025.
In some cases, if your trust holds an investment portfolio that is managed on a discretionary basis by an investment manager, this could result in a trust being treated as a Reporting Financial Institution (RFI) for AEOI purposes. If the trust is an RFI and is not already registered, registration may be required by the deadline.
Where a trust is instead classified as a Non-Financial Entity (NFE) / Non-Financial Foreign Entity (NFFE), registration will not be needed. This registration requirement does not change existing CRS or FATCA reporting arrangements.
As a trustee, you are responsible for registering your trust if it is classified as a Financial Institution for AEOI purposes. It could be liable for a penalty if it is deemed to require HMRC registration but has not done so by the 31st December 2025 deadline. It is advisable to check whether your trust is classified as a Financial Institution or Non‑Financial Entity. If it is a Financial Institution and is not already registered, you will need to complete HMRC registration by 31st December 2025 online via HMRC’s AEOI service (use the “Register now” option on the HMRC Automatic Exchange of Information registration page: Register for Automatic Exchange of Information - GOV.UK). You will need Government Gateway login details to complete the registration process.
The information provided in this article is of a general nature and is not a substitute for specific advice with regard to your own circumstances. You are recommended to obtain specific advice from a qualified professional before you take any action or refrain from action.
