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Major TRS Changes for 2025: A New Compliance Era for UK Trusts
The UK government is making big changes to the Trust Registration Service (TRS) to strengthen anti-money laundering (AML) rules while making it easier for lower-risk trusts. These changes will take effect in 2025 and will affect both UK and non-UK trustees. It’s important to understand these updates to remain compliant and avoid penalties.
What Is the Trust Registration Service?
The TRS is an HMRC-operated system requiring most UK and some overseas trusts to register trust details, including:
- Settlor, trustee, and beneficiary information
- Trust assets
- Contact and tax-related information
It’s also the only way to obtain a Unique Taxpayer Reference (UTR) for a trust in the UK.
Key 2025 TRS Updates at a Glance
1. Non-UK Trusts Holding UK Property Now Must Register: Under new rules, non-UK express trusts that acquired UK land before 6 October 2020 and still hold it when the legislation kicks in must register, even if they’re not liable for UK tax. This closes a longstanding loophole.
These trusts will also be subject to data-sharing rules, meaning HMRC may release information to third parties investigating financial crime, provided they have a legitimate interest.
2. New Exemption for Small, Low-Risk Trusts: A new de minimis exemption is being introduced for trusts created after the new law comes into force. Trusts will be exempt from registration if they meet all of the following:
- No liability for UK tax
- No ownership of UK property
- Assets worth £10,000 or less
- Income of £5,000 or less per year
- Non-financial assets (like jewellery or antiques) under £2,000
Once any threshold is exceeded, the trust becomes permanently registrable.
3. Simplified Rules for Death-Related Trusts: Trusts created upon or shortly after a settlor’s death will now have a two-year exemption period before registration is required. This includes:
- Property co-ownership trusts
- s.34 Trustee Act 1925 trusts (triggered when a trustee dies)
- Trusts created by a deed of variation during estate administration
This change aligns death-related trust treatment with existing will trust exemptions.
4. Scottish Survivorship Trusts Exempt: Scottish survivorship destination trusts, which redirect property ownership through survivorship clauses, will be completely exempt from TRS registration in the future.
When Will These Rules Take Effect?
The government will amend the Money Laundering Regulations through a Statutory Instrument, expected in the latter half of 2025. A draft version will be published first for technical feedback before Parliament gives final approval.
What Should Trustees Do Now?
- Audit your trust holdings—especially if you manage a non-UK trust with UK property.
- Evaluate small trusts to see if they might qualify for the new de minimis exemption.
- Note key deadlines—some trusts will still need to register within 90 days of creation.
- Stay informed—monitor HMRC updates and prepare for a faster registration turnaround.
Prepare for Stricter Rules and New Flexibility
These updates are designed to strike a balance between transparency and compliance burden. While high-risk, non-UK trusts face tighter rules, low-value UK trusts may finally benefit from simplified reporting.
If you’re a trustee, don’t wait until the new rules become law—review your trust structures now to avoid last-minute registration issues and ensure you’re compliant from day one.