There have recently been changes to the UK’s Automatic Exchange of Information (AEOI) regulations. AEOI is an international reporting framework designed to provide tax authorities with information on overseas financial assets, including stocks, shares and bonds, to ensure accurate tax compliance..
Under AEOI, certain UK Financial Institutions are required to identify non-UK “account holders” (for example, non-UK resident beneficiaries of a UK trust), maintain appropriate records, and report relevant information to HMRC
All UK Financial Institutions are now required to register directly with HMRC for AEOI purposes. Up until recently, it was understood these regulations would not impact trusts. However, HMRC recently updated its guidance on 4 December 2025, confirming trusts are included within the definition of a “Financial Institution”. As a result, additional reporting obligations now apply to some trustees.
The deadline to register is 31 December 2025. As a result, Trustees need to act quickly to establish the position, and register with HMRC where required.
Registration for the purposes of AEOI is separate and additional to registration for other purposes such as the Trust Registration Service (TRS) or registration for Self-Assessment.
HMRC may impose penalties for failure to comply with the registration requirements. These may include a penalty of up to £1,000, as well as a daily penalty of up to £300 for ongoing non-compliance.
If you are a trustee and are unsure of your registration requirements, contact a member of the team today.
