The Trust Registration Service
Written and reviewed by the Trust Tax Accountants editorial team. Last reviewed 22 August 2026.
- What is due
- Register the trust on HMRC's Trust Registration Service
- By when
- Within 90 days of the trust being created or becoming liable for tax
- If it is missed
- £5,000
Most people who become trustees do not find out about the Trust Registration Service until something else goes wrong. It is not a tax return and it is not optional, and the reach is much wider than trustees expect: registration is not limited to trusts that pay tax.
This is who has to register, by when, and what has to be kept current afterwards.
Which Trusts Have to Register
Two groups. The first is any trust with a tax liability: UK resident trusts liable to income tax, capital gains tax, inheritance tax, stamp duty land tax or the related property taxes, and non-resident trusts that become liable to those taxes on UK assets or income.
The second is the one that catches people. All UK resident express trusts have to register unless they fall within a specific exclusion, whether or not they pay any tax at all. A trust created deliberately by a settlor, which is what express means, is in scope by default. Non-resident trusts with UK links are also caught, including those acquiring UK land after 6 October 2020.
There are excluded categories, set out as Schedule 3A trusts in HMRC's registration guidance. Assuming you fall inside one without checking is the common and expensive mistake.
The Deadlines
For a trust created after 6 October 2020, the deadline is 90 days from the trust being created or from it becoming liable for tax, whichever applies.
For older trusts there is a separate rule worth knowing if you have inherited a long-running trust. A trust created before 6 April 2021 that became liable to income tax or capital gains tax for the first time had to register by 5 October in the tax year after the liability arose.
The registration itself is not the end of it. Trustees have to keep the register up to date as things change: trustees appointed or retired, beneficiaries added, the trust wound up. The obligation is continuous, not a one-off.
The Penalty, and Why It Is Not the Real Risk
Failing to register can attract a £5,000 penalty. That is the headline, and it is the number most guidance stops at.
The practical risk is usually worse and arrives sooner. An unregistered trust cannot get the reference it needs to deal with HMRC cleanly, which stalls the trust and estate tax return and anything else that depends on it. Banks, registrars and other institutions increasingly ask for proof of registration before they will act on a trustee's instruction, so an unregistered trust can find itself unable to transact at all.
The registration regime sits under the money laundering rules rather than the tax code, which is why the reach is so wide and why it applies to trusts with no tax to pay. The underlying obligations come from the Money Laundering Regulations 2017.
What We Do
Register the trust, or work out first whether it needs to be registered, which is the more useful question when someone has just been appointed and does not know what they are holding. Where a trust should have been registered years ago we deal with the late registration rather than leaving it hanging.
After that, keeping the register current alongside the annual filing, so the two do not drift apart. That runs as part of the ongoing compliance work rather than as a separate engagement.