Jurisdiction(s):
United Kingdom

UK trustees’ AEOI (CRS/FATCA) compliance checklist: classification, registration, due diligence, reporting, notifications, penalties and governance under the International Tax Compliance Regulations 2015

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Checklists

Automatic Exchange of Information (AEOI) is the worldwide benchmark for routinely transmitting taxpayers’ financial details between jurisdictions to deter tax evasion. A trust resident in the UK is generally brought within the UK AEOI framework through the International Tax Compliance Regulations 2015 (SI 2015/878), as amended (the ‘ITC Regulations’). The ITC Regulations give domestic effect to the UK’s AEOI commitments under the Common Reporting Standard (CRS) and the UK‑US FATCA Agreement (FATCA). Refer to Practice Notes: Automatic exchange of information-outline; Automatic exchange of information for UK trustees-key obligations; and FATCA and UK Trusts. HMRC’s guidance appears in the International Exchange of Information Manual (IEIM400000). This Checklist summarises the principal matters trustees must consider under the UK AEOI regime.

Scope and Threshold Question: Does AEOI Apply?

Has the trust’s UK tax residence position been determined for AEOI purposes?
Has it been verified whether the ITC Regulations 2015 apply to the trust (CRS and/or FATCA)?
Is the trust in scope of AEOI as a possible Financial Institution (FI), or alternatively a Non‑Financial Entity (NFE) for CRS or a Non‑Financial Foreign Entity (NFFE) for FATCA?

Classification of the Trust Financial Institution (FI) Analysis

Does the trust...

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Web page updated on 27/05/2026

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