Jurisdiction(s):
United Kingdom

UK AEOI overhaul (SI 2025/740): mandatory HMRC registration for reporting and trustee‑documented trusts, deadlines, penalties, registration, and expanded CRS/FATCA, self‑certification and crypto‑asset reporting

Published on: 29 January 2026

Published by a LexisNexis Private Client expert

Legal News

Article summary

What is the background to the Regulations?

The International Tax Compliance (Amendment) Regulations 2025, SI 2025/740 (the Regulations) came into force on 16 July 2025. They revise the International Tax Compliance Regulations 2015, SI 2015/878—the UK’s framework for AEOI under the CRS and the US FATCA. A central change is compulsory HMRC registration for in‑scope trusts (and other relevant ‘financial institutions’, potentially including e-money institutions and family investment companies). This new obligation may extend to trusts that previously had no AEOI duties, so UK trustees and their advisers should be alert to it and respond promptly. The policy aim is to give HMRC visibility across all UK financial institutions, regardless of whether they must file periodic AEOI reports. In essence, the measure broadens HMRC oversight and ensures comprehensive institutional visibility across the sector.

Which trusts need to register?

All trusts that are ‘reporting financial institutions’ or ‘specified non-reporting financial institutions’ (often called ‘trustee-documented trusts’) must register with HMRC. Typically, a trust will be a financial institution if:

it is managed by another financial institution, eg:
- its trustee is a professional entity that administers the trust in the course of its business, or
- its assets are overseen by a fund manager...

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