Mandatory Common Reporting for Trusts: What you need to know

Published by Gary Hicks on 15 January 2026

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Recent changes to the UK’s Automatic Exchange of Information (AEOI) regulations mean that all UK Financial Institutions must now register directly with HMRC — even where they have no reportable accounts.

This includes certain trusts that fall within the definition of a Financial Institution under AEOI rules. 

Why does this matter for trusts?

Under the updated rules (often referred to as CRS2.0), trusts that receive more than 50% of their income from managed investment portfolios are now required to register with HMRC, even if there is nothing to report. Previously, registration was only necessary if reportable accounts existed. 

What you need to do

Trustees must register their trust with HMRC here.

To complete registration, you’ll need to set up a new organisation Government Gateway account and have the following details ready: 

  • Trust name and lead trustee’s contact details 
  • A phone number and email address 
  • The trust’s GIIN (Global Intermediary Identification Number). You can check if your trust has a GIIN here (or use 000000.00000.LE.000 if not applicable) 
  • The trust’s UTR (Unique Taxpayer Reference) 
  • The trust’s main address 

If the trust has any accounts that need to be reported, an annual return must also be submitted by 31 May each year.

Penalties and timing

HMRC can apply penalties if a trust doesn’t register or report by 31 December 2026. However, given the short notice of these changes, HMRC has indicated it will take a reasonable approach if registration occurs early in 2026. Even so, we recommend completing the registration as soon as possible. 

Need advice or support?

If you have any questions or would like to discuss next steps, please contact your usual Kreston Reeves adviser or get in touch with us directly.

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