Changes to the Trust Registration Service: What you need to know 

The rules around the Trust Registration Service are changing, and if you are a trustee, a settlor, or someone with an interest in a trust that has any connection to the UK, it is worth understanding what is coming and whether you need to act. 

The reforms stem from the government’s July 2025 response to a consultation on anti-money laundering regulations. Draft changes were initially published in September 2025, but the statutory instrument was approved on 8^th June 2026 and is expected to come into force imminently. Some of these changes will catch people off guard. 

If your trust holds UK land, the registration rules are changing 

The most significant change in the new rules concerns non-UK express trusts that hold UK land, and it will catch a number of trustees who have never previously needed to engage with the TRS. 

Under the current rules, a non-UK trust only needs to register with the TRS if it acquired UK land on or after 6^th October 2020, or if something else triggered a registration obligation. The new rules remove that boundary entirely. 

From the point the new rules come into force, any non-UK express trust that owns or has an interest in UK land will need to register, regardless of when that land was acquired. It does not matter that nothing has changed in the trust’s structure, or that there has been no transaction, no new trustee, no other trigger. If the trust still holds the land when the rules change, registration will be required. 

This is the government’s deliberate response to concerns about overseas ownership of UK property and the risks that opacity in that area can create. For trustees who have been managing a trust with UK land interests for many years without ever needing to register, this will come as a genuine surprise. The time to look at this is now, before the rules are in place. 

Who can see your trust information is also changing 

Alongside the registration changes, the data-sharing rules are being broadened. At the moment, data sharing under the TRS applies to trusts with at least one UK-resident trustee. Under the new framework, all non-UK express trusts with UK land interests will be subject to data sharing, whatever the residency of their trustees. 

The important reassurance is that information will only be disclosed to those who can demonstrate a legitimate interest in accessing it. Casual or speculative enquiries will not be entertained. Where a beneficial owner could face a genuine risk of harm if their details were disclosed, there is a formal route to apply for that information to be protected. For trustees and beneficiaries with more sensitive arrangements, taking advice on this provision before the rules take effect is sensible. 

Post-death trusts 

For trusts that arise through estate administration, the new rules bring a more consistent approach to registration deadlines. Co-ownership property trusts and trusts created by deed of variation will have 90 days from the date of creation or death to register. Will trusts already benefit from a two-year registration exemption under the current regime, and that is being retained. Section 34 Trustee Act 1925 trusts and trusts created by a deed of variation on death will now also qualify for the two-year exemption, bringing them into line with Will trusts. For executors and trustees managing complex estates involving multiple trusts, this alignment is a welcome simplification. 

Small trusts 

A new minimum threshold exemption will be available for certain small, low-risk trusts, meaning that trusts falling below specified limits will not need to register at all. To qualify, a trust must meet all of the following conditions: no liability for UK taxes of any kind, no interest in UK land or real property, total assets not exceeding £10,000, annual income not exceeding £5,000, and non-financial assets such as art or jewellery not exceeding £2,000 in value. 

Two points deserve attention here. The exemption only applies to trusts created after the new rules come into force, so an existing small trust that has never been registered cannot rely on this provision. Additionally, if a trust qualifies initially but later crosses any of those thresholds, it becomes registrable and remains so even if its value subsequently drops back down. It is worth checking your position carefully rather than assuming you are covered. 

SDRT is no longer a trigger for registration 

There is one straightforward simplification that will likely be received well, and that is that stamp duty reserve tax liability will no longer, by itself, require a trust to register with the TRS. For non-UK trusts with no other UK connections, this removes a registration obligation that could previously arise in limited circumstances. 

What to do before the rules change 

The earlier you look at this, the better placed you will be. If you are a trustee, now is a good time to review any unregistered trusts and consider whether they will fall within the new rules. Gathering the information needed for TRS registration takes time, covering details of the trust itself, the trustees, settlors, beneficiaries, and anyone else exercising effective control. 

If your trust holds UK land and has not previously needed to register, these changes represent a real shift in your obligations. Understanding your position before the rules take effect is far easier than trying to catch up afterwards. Coodes’ private client team is here to help you work through what these changes mean for your specific circumstances. 

About the author: Jane Drummond is a Chartered Tax Advisor and member of both the Association of Tax Technicians and the Chartered Institute of Taxation, and is experienced across personal, business, trust and estate tax compliance and advisory work. Jane manages a portfolio of trusts on behalf of professional and lay trustees, advising on HMRC compliance, Self-Assessment and Inheritance Tax matters, and ensuring trusts are correctly registered with the Trust Registration Service. She works closely with trustees, beneficiaries and personal representatives throughout the administration of estates. 

Get in touch: jane.drummond@coodes.co.uk 01566 770013