Trust Tax Accountants

The Trust Registration Service

Written and reviewed by the Trust Tax Accountants editorial team. Last reviewed 22 August 2026.

What is due
Register the trust on HMRC's Trust Registration Service
By when
Within 90 days of the trust being created or becoming liable for tax
If it is missed
£5,000

Most people who become trustees do not find out about the Trust Registration Service until something else goes wrong. It is not a tax return and it is not optional, and the reach is much wider than trustees expect: registration is not limited to trusts that pay tax.

This is who has to register, by when, and what has to be kept current afterwards.

Which Trusts Have to Register

Two groups. The first is any trust with a tax liability: UK resident trusts liable to income tax, capital gains tax, inheritance tax, stamp duty land tax or the related property taxes, and non-resident trusts that become liable to those taxes on UK assets or income.

The second is the one that catches people. All UK resident express trusts have to register unless they fall within a specific exclusion, whether or not they pay any tax at all. A trust created deliberately by a settlor, which is what express means, is in scope by default. Non-resident trusts with UK links are also caught, including those acquiring UK land after 6 October 2020.

There are excluded categories, set out as Schedule 3A trusts in HMRC's registration guidance. Assuming you fall inside one without checking is the common and expensive mistake.

The Deadlines

For a trust created after 6 October 2020, the deadline is 90 days from the trust being created or from it becoming liable for tax, whichever applies.

For older trusts there is a separate rule worth knowing if you have inherited a long-running trust. A trust created before 6 April 2021 that became liable to income tax or capital gains tax for the first time had to register by 5 October in the tax year after the liability arose.

The registration itself is not the end of it. Trustees have to keep the register up to date as things change: trustees appointed or retired, beneficiaries added, the trust wound up. The obligation is continuous, not a one-off.

The Penalty, and Why It Is Not the Real Risk

Failing to register can attract a £5,000 penalty. That is the headline, and it is the number most guidance stops at.

The practical risk is usually worse and arrives sooner. An unregistered trust cannot get the reference it needs to deal with HMRC cleanly, which stalls the trust and estate tax return and anything else that depends on it. Banks, registrars and other institutions increasingly ask for proof of registration before they will act on a trustee's instruction, so an unregistered trust can find itself unable to transact at all.

The registration regime sits under the money laundering rules rather than the tax code, which is why the reach is so wide and why it applies to trusts with no tax to pay. The underlying obligations come from the Money Laundering Regulations 2017.

What We Do

Register the trust, or work out first whether it needs to be registered, which is the more useful question when someone has just been appointed and does not know what they are holding. Where a trust should have been registered years ago we deal with the late registration rather than leaving it hanging.

After that, keeping the register current alongside the annual filing, so the two do not drift apart. That runs as part of the ongoing compliance work rather than as a separate engagement.

Common questions

Does a trust have to register if it pays no tax?
Usually yes. All UK resident express trusts must register unless they fall within a specific exclusion, whether or not there is any tax to pay. Registration is not limited to taxable trusts.
What is the deadline to register a trust?
Within 90 days of the trust being created or of it becoming liable for tax. Trusts created before 6 April 2021 that first became liable to income tax or capital gains tax had to register by 5 October in the tax year after that liability arose.
What is the penalty for not registering?
Up to £5,000. In practice the bigger problem arrives earlier: an unregistered trust struggles to deal with HMRC and increasingly cannot satisfy banks and registrars who ask for proof of registration before acting.
The trust was registered years ago. Is there anything ongoing?
Yes. The register has to be kept up to date as trustees change, beneficiaries are added, or the trust is wound up. It is a continuing obligation rather than a single filing.

Find out what it costs before you commit

Tell us what kind of trust it is, whether it is registered, and what is outstanding. We come back with a fixed price and the date each filing has to be in by.

Tell us about the trust or estate
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