New TRS rules now in force — what trustees need to know

Significant changes to the Trust Registration Service (TRS) came into force on 30 June 2026 under the amended Money Laundering and Terrorist Financing Regulations 2026 (SI 2026/621). 

Designed to increase transparency while reducing unnecessary administration for lower-risk trusts, the reforms will affect many trustees and professional advisers.

Here, Trust Manager Melissa Benyon from our private client team explores the key changes to the TRS, explains what they mean in practice and outlines the steps that trustees should be taking now.

What is the TRS?

The TRS is HMRC's online register of trusts and their beneficial owners. Introduced as part of the UK's anti-money laundering framework, the TRS helps to improve transparency around trust ownership and control.

Trustees are responsible for ensuring that registrable trusts are correctly recorded on the TRS and that the information held remains accurate and up to date. Registration generally applies to taxable trusts and certain non-taxable express trusts, with trustees required to provide details of the trust's settlor, trustees, beneficiaries and — where relevant — the trust assets.

Expanded registration requirements for non-UK trusts

One of the most notable changes extends the scope of the TRS to include certain non-UK trusts holding UK land or property.

Previously, many non-UK trusts were only required to register if they incurred a UK tax liability. From 30 June 2026, non-UK trusts that acquired an interest in UK land or property before 6 October 2020 and continue to hold that interest may now be required to register, even where no UK tax liability arises.

Trustees impacted by these changes have been given a transitional period, with registrations generally required by 1 September 2027.

New de minimis exemption

In a welcome simplification, a new de minimis exemption has been introduced for certain low-risk, low-value trusts.

To qualify, a trust mustn’t:

• Own or hold an interest in UK land or property.
• Hold assets with a value exceeding £10,000.
• Have an annual income of more than £5,000.
• Hold significant non-financial assets such as artwork, jewellery or antiques worth £2,000 or more.
   

The exemption aims to remove unnecessary compliance obligations where the money laundering risk is considered minimal.

Extension of the two-year registration exemption

The regulations also extend the two-year registration exemption for certain trusts arising on death.

Under the previous rules, some arrangements had to be registered within 90 days of creation despite existing solely as part of estate administration. The revised rules provide additional breathing space for trustees and personal representatives.

The extended exemption now applies to:

1. Trusts created by a deed of variation during the administration of a deceased person's estate.
2. Co-ownership trusts that become registrable following the death of a relevant individual.
3. Statutory trusts arising under section 34 of the Trustee Act 1925 where registration is triggered by a death.
    

These changes should significantly reduce the administrative burden during estate administration.

Changes to information sharing

The reforms also introduce changes to the TRS information-sharing regime.

Certain individuals and organisations with a legitimate interest in preventing or investigating money laundering, terrorist financing or other specified criminal activity may now be able to request information held on the TRS in prescribed circumstances. Additional provisions also apply to certain trusts connected to non-EEA entities.

While trust information isn’t publicly accessible in the same way as Companies House records, trustees should be aware that information provided to HMRC may be disclosed where permitted by law.

What should trustees do now?

Trustees should review existing trust arrangements to determine whether the new rules affect their registration obligations. 

This is particularly important for:

• Non-UK trusts holding UK property.
• Trusts created following a death.
• Trusts that may qualify for the new de minimis exemption.
• Existing TRS registrations that may require updating.
   

How we can help

Our specialist private client team can assist trustees with all aspects of TRS compliance, including new registrations, updates to existing records and assessing the impact of the 2026 changes. 

We can help to determine whether a trust falls within the registration requirements, qualifies for an exemption or requires action under the revised rules, ensuring that trustees remain compliant while minimising unnecessary administrative burdens.

Talk to us by giving us a call on 0333 004 4488, sending us an email at privateclient@brabners.com or completing our contact form.