A Quiet Change With Real Consequences
On 30 June 2026, amended money laundering regulations changed the rules for the Trust Registration Service. The reform widens registration requirements for some trusts — particularly certain non-UK trusts with UK connections — while introducing welcome easements for lower-risk arrangements.
It received almost no coverage in the mainstream press. That is a problem, because the duty to register sits with trustees personally, and “I did not know the rules had changed” has never been a defence.
If you are a trustee of a family trust — a life interest trust in a Will, a discretionary trust holding the family home, a trust set up for grandchildren, or a trust holding a business interest — this applies to you.
What the Trust Registration Service Is
The TRS is HMRC’s register of trusts, created to meet anti-money-laundering obligations. Most UK resident trusts, and non-UK resident trusts with certain UK links, must be registered. Trustees must record details of the trust, the settlor, the trustees, the beneficiaries or classes of beneficiary, and any other person with control.
Registration is not a tax return. A trust with no income and no tax liability can still be registrable. That is the single most common misunderstanding we see.
What Changed on 30 June 2026
Wider scope in places
The changes extend registration duties to some non-UK trusts that previously fell outside the net, including trusts with UK connections that had relied on the narrower pre-2026 tests. Trusts that only became registrable because they incurred a UK tax liability need to be looked at again against the amended tests.
Easements for lower-risk trusts
Balancing that, the regulations introduce exemptions and simplifications for categories of trust regarded as low risk. This is genuinely helpful — a number of small, simple family arrangements that were caught by the old rules may no longer need to be registered, or may face lighter requirements.
The practical consequence
Because the changes cut both ways, the only safe approach is to check each trust against the current rules rather than relying on advice given before June 2026. A trust that was correctly unregistered in 2025 may be registrable now — and vice versa.
The Deadlines Trustees Miss
Two duties catch trustees out repeatedly.
Registration. New trusts must generally be registered within 90 days of creation, and taxable trusts have separate deadlines linked to tax liabilities. Trusts created by a Will are frequently overlooked entirely, because the family thinks of the process as “probate” rather than “we have just created a trust”.
Keeping the record up to date. This is the duty most trustees do not know exists. If a trustee dies, retires or is appointed; if a beneficiary is added; if the trust’s assets or address change — the register must be updated, generally within 90 days of the trustees becoming aware. Taxable trusts must also confirm the register annually.
Penalties and Practical Risk
HMRC’s stated approach has been educative for first, innocent failures, with a nudge letter rather than an immediate fine. That does not mean the risk is theoretical. Deliberate or repeated failures attract penalties, and there are two commercial consequences trustees feel sooner:
- You cannot easily transact. Banks, conveyancers, accountants and investment platforms ask for proof of registration. Without it, sales, mortgages and account openings stall.
- Trustee exposure is personal. Trustees are jointly responsible. A passive trustee who left it to a sibling is still on the hook.
A Trustee’s Practical Checklist
- List every trust you are a trustee of. Include trusts created by a Will, trusts holding life policies, and any declaration of trust over property. People routinely forget one.
- Check registrable status against the post-30 June 2026 rules — not the version you were advised on previously.
- Find your Unique Reference Number for each registered trust and store it with the trust deed. You will need it for every update and for proof of registration.
- Reconcile the register with reality. Trustees, beneficiaries, addresses, assets. Correct anything out of date within 90 days.
- Diarise the annual confirmation for taxable trusts.
- Keep proper trustee records. Minutes of decisions, distributions, and investment reviews. The register is one duty among several — trustees also owe duties of care, impartiality and record-keeping to beneficiaries.
- Ask about the ten-year charge. Relevant property trusts face a principal charge every ten years. Many family trusts set up in the 2010s are now approaching theirs, and the reporting is easy to miss.
None of This Is a Reason to Avoid Trusts
Trusts remain the most effective tool available for protecting a family home from being lost to a second marriage, ring-fencing an inheritance from a beneficiary’s divorce or creditors, providing for a vulnerable child, and controlling when and how young beneficiaries receive money. The compliance is administrative, and it is manageable once someone is clearly responsible for it.
The failures we see are almost never failures of the trust structure. They are failures of housekeeping — a trust created ten years ago, the adviser long since retired, and nobody quite sure who is looking after it.
If you are a trustee and you are not certain your trust is registered, up to date, and compliant with the rules that took effect on 30 June 2026, that is a half-hour conversation worth having now rather than when a bank asks for the paperwork.