Automatic Exchance of Information with HMRC – AEOI and Trusts
HMRC released new guidance on 16 December 2025 notifying Trustees of an obligation to register some trusts under the new rules for Automatic Exchange of Information (AEOI).
What do we know about AEOI and trusts (Automatic Exchange of Information)?
This obligation has arisen from amendments to the “International Tax Compliance Regulations 2025” which impose a new mandatory registration requirement for trusts which are defined as “financial institutions” (FI) or “trustee-documented trusts” (TDT). The registration is to facilitate international tax information exchange. The registration deadline with HMRC is 31 December 2025.
Very broadly, a trust will be a ” financial institution” for these purposes if:
- it holds financial assets (for example, an investment portfolio) and these are professionally managed, or
- the trust has a corporate trustee.
There are exemptions that mean an FI trust can be classified as “non-reporting”, but these are narrow, and the vast majority of FI trusts will be within scope of these new rules.
A trust will be “trustee documented” if it has a “reporting FI” as a trustee (such as a corporate trustee) and that trustee reports on behalf of the trusts it manages.
Previously, registration for trusts that are FIs or TDTs was necessary only in circumstances where the trust had a “reportable person” which, very broadly, meant a beneficiary, trustee or settlor who was tax-resident in another jurisdiction. The recent updates made to the regulations now require all FIs and TDTs to register with HMRC’s “automatic exchange of information” (AEOI) service irrespective of whether they have reportable persons to declare or not.
The action to take now is to review your trust’s assets and how they are managed to check if, as a trustee, you have an obligation to register with HMRC under the AEOI regime. Please note that HMRC published the initial penalty for non-registration when it is required as £1,000.
What should you do if you need help with AEOI and Trusts?
Should you require any assistance with AEOI and trusts, if you need help with the registration or if you have questions as to whether your trust needs to be registered, please do not hesitate to contact us and we will be happy to assist. You can contact us at hello@rpgcc.co.uk or you can call us on 020 7870 9050.
