Navigating AEOI Compliance for UK Trusts
Automatic Exchange of Information (AEOI): Registration Requirement for UK Trusts with Discretionary Managed Investment Portfolios
At Fiander ETL, we wish to highlight recent amendments to the UK’s Automatic Exchange of Information (AEOI) regime, introduced in line with HM Revenue & Customs (HMRC) guidance and international standards set by the Organisation for Economic Co-operation and Development (OECD).
These updates place new registration obligations on certain UK trusts, specifically those with discretionary managed investment portfolios.
The changes form part of the UK’s commitment to global tax transparency and information sharing, with HMRC acting as the responsible authority for implementing and overseeing these requirements.In the past, only UK trusts with non-resident individuals connected to them were required to register. However, trustees are now obligated to complete a one-time AEOI registration with HMRC, regardless of whether any non-UK tax resident individuals are associated with the trust.Below is a summary of these updates, explaining who may be affected and outlining the practical steps trustees may need to take.
Who is Affected?
The new requirement is relevant to UK trusts that:
- Derive most or all of their income and gains from investments; and
- Have investments managed on a discretionary basis by a financial institution
Such trusts are now required to register for AEOI purposes directly with HMRC, even where they were not previously required to do so.
What Should Trustees Do Now?
If you are a trustee of a UK trust with a discretionary managed investment portfolio, you will need to ensure your trust is registered with HMRC by 31 December 2025.The lead trustee will need to set up (or use an existing) Government Gateway account and provide details of the trust, as required. Registration can be accessed via the HMRC website:
Where a trust has no non-UK resident beneficiaries, registration should generally be a one-off requirement, provided the trust’s circumstances do not change.
Penalties for Non-Compliance
HMRC has confirmed that penalties may apply where a trust is required to register and fails to do so within the prescribed timeframe. Trustees should therefore promptly assess whether these changes apply to their trust, and, if so, ensure registration is completed by the deadline.
Still Not Sure?
Due to the way HMRC’s systems operate, Fiander ETL are unable to complete the AEOI registration on behalf of trustees.If you are uncertain whether these changes affect your trust, you can contact us for further guidance or speak with the investment manager or financial institution responsible for managing the trust’s assets, who may also be able to confirm whether the trust is affected.
