SearchNew HMRC AEOI registration requirement – what trustees and directors need to know
We have recently been made aware of a new HMRC registration requirement under the UK’s Automatic Exchange of Information (AEOI) rules, which form part of the international Common Reporting Standard (CRS) framework.
HMRC now requires certain trusts and companies to register for its AEOI service. For many existing arrangements, the deadline to register is 31 December 2025.
We will be working with clients in the new year to identify which entities may be affected. The rules are technical and highly fact-specific, depending on matters such as how an entity is managed and the nature of its income. However, both HMRC and professional bodies have indicated that the requirement may apply more widely than initially expected, including to some family trusts and private companies.
What do the rules mean?
A trust or company may need to register if it is treated as either:
a Reporting Financial Institution, or
a Trustee-Documented Trust
for CRS purposes. Importantly, registration may still be required even where there is no information to report.
For trusts, the most common circumstances in which registration is required are where:
50% or more of the trust’s income arises from investments, and
the trust’s assets are professionally managed (for example, by a discretionary fund manager).
We are continuing to review the position for investment companies, where the rules differ from those applying to trusts and may be less likely to result in a registration obligation.
Key deadline
HMRC’s stated deadline for registration is:
31 December 2025, or
if later, 31 January following the calendar year in which the trust or company first becomes a Reporting Financial Institution or Trustee-Documented Trust.
Who is responsible?
Responsibility for compliance rests with:
the trustees, in the case of a trust, or
the directors, in the case of a company.
They are required to ensure that registration is completed where necessary.
What should you do now?
We recommend that you:
consider whether your trust or company may fall within scope of the AEOI rules;
ensure registration is completed by the relevant deadline where required (registration is completed online via Government Gateway); and
contact us after 5 January 2026 if you would like our assistance in assessing your position, registering with HMRC and supporting ongoing compliance.
Information typically required for registration
HMRC’s registration process generally requires:
contact details;
the trust or company’s UTR; and
where applicable, a FATCA GIIN (a US tax reference number, which will not apply in all cases).
If you choose to register directly, HMRC guidance and the registration link can be found here:
https://www.gov.uk/guidance/register-for-automatic-exchange-of-information
HMRC’s AEOI helpline number is 03000 576 748.
Penalties and HMRC’s approach
HMRC has indicated that it will not issue automatic late filing penalties where genuine efforts are being made to comply and register. However, HMRC guidance confirms that failure to register where required may result in penalties, including:
an initial penalty of up to £1,000, and
potential daily penalties if the failure continues after HMRC has issued a notice.
If you would like to discuss how these rules may affect your trust or company, please contact your usual HURST adviser.