The expansion of UK Trust Registration Services

• The UK’s Trust Registration Service (TRS) rules have been amended to include registration requirements for certain non-UK trusts holding UK real estate.
• The changes form part of the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 and came into force with effect from 30 June 2026.
• They are particularly relevant to institutional real estate structures, including Jersey Property Unit Trusts (JPUTs) and Guernsey Property Unit Trusts (GPUTs).

• The TRS is HMRC’s online register for trusts. It collects information on trusts for UK tax administration and anti-money laundering purposes.
• It was implemented to help HMRC understand more about trusts in existence with a UK footprint.
• The registration is made with HMRC and the details are not publicly available. The TRS requires the trustee to provide details of:
  • The Trustee(s)
  • The Settlor(s)
  • The Beneficiaries
  • Any Protectors
  • Details of any company based outside the EU, Norway, Iceland or Liechtenstein where the trust has a controlling interest in that company
• The registration must be updated to reflect any change in circumstances.

• Previously, a non-UK trust generally became registrable where it directly acquired UK land on or after 6 October 2020.
• The 2026 changes extend TRS registration to certain non-UK trusts that acquired UK land before 6 October 2020 and continued to hold that interest as at 30 June 2026.
• In practical terms, this brings many long-established offshore real estate holding structures, including JPUTs and GPUTs, within scope.
• Trusts now brought within scope must register by 1 September 2027.

• The amendments form part of the Government’s wider anti-money laundering and beneficial ownership transparency reforms, building on the introduction of the Register of Overseas Entities and Authorised Corporate Services Provider (ACSP) requirements in recent years.
• The intent is to improve the effectiveness and transparency of[GS1]  the UK’s Money Laundering Regulations and Trust Registration Service framework and therefore the confidence in UK business decision-making processes generally.

• Many JPUTs and GPUTs previously fell outside the TRS regime since the relevant UK property was acquired before the 6 October 2020 date threshold was introduced.
• Trustees should now no longer assume that a historic acquisition date removes the need for registration.
• JPUTs, GPUTs and other non-UK express trusts that continue to hold UK real estate should review whether they are now registrable under the expanded rules.
• Although there are exemptions for certain very small, low-risk trusts, nearly all JPUTs and GPUTs should be assumed to be registrable where[GS2] [SP3]  they continue to hold UK property directly.
• Even nominee relationships can be caught and required to be registered, so careful consideration needs to be given to the registration requirements to ensure compliance.

Failure to register affected trusts before the deadline risks a £5,000 penalty payment.