Updates to UK beneficial ownership registers – what trustees need to know

Introduction

On 17 July 2025, the Government published its long-awaited response to the 2024 consultation¹ on the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), confirming a series of updates to the UK Trust Registration Service (TRS). These reforms introduce both new obligations and welcome simplifications for trustees.

TRS: What's changing?

1. Registration expanded to all non-UK express trusts holding an interest in UK land

Under the existing rules, non-UK express trusts are only required to register on the TRS if they acquire UK land on or after 6 October 2020, or if another registration trigger applies.

The new rules will require all non-UK express trusts that own or have an interest in UK land—regardless of when the land was acquired—to register on the TRS, provided the trust still holds the land on the date the amended regulations come into force. This means that even if a trust acquired UK property many years ago and has not since changed its structure or triggered another registration event, it will now be brought within the scope of the TRS if it continues to own the property when the new rules take effect.

This change is intended to close the perceived "reporting gap", with the consultation response specifically citing concerns around the opacity of overseas ownership of UK real estate and the associated risks of money laundering and tax evasion.

How many trusts will actually be impacted by this change remains to be seen as if the trustee has a UK tax liability in relation to UK property (i.e. a UK income tax liability on the property’s rental income) then TRS reporting is required in any event.

2. Broader data sharing

The TRS data sharing regime will also be expanded to cover a wider range of non-UK express trusts with UK land interests. Previously, the ability for third parties to request information reported on the TRS about non-UK trusts was limited to those trusts that had at least one UK-resident trustee. Under the new rules, this distinction will be removed.

In practice, information about these trusts should only be accessible to third parties who can demonstrate a “legitimate interest". Requests from the general public that are casual or speculative in nature will not be allowed, which should help to alleviate any privacy concerns.

3. Unified registration deadline for trusts connected to an estate

The updated TRS regime will introduce a unified approach to the registration deadlines for trusts that arise in connection with the administration of estates, such that the two-year exemption for registration will apply to:

Will trusts (i.e. trusts arising under a Will following the testator's death) – which already benefit from the two-year exemption under the current TRS regime;
Co-ownership property trusts which become registrable as a result of the trustee or other relevant person's death;
Trusts created under section 34 of the Trustee Act 1925 which become registrable as a result of the trustee or other relevant person's death
Trusts created by a deed of variation.

4. Introduction of a "de minimis" exemption for small trusts

A new "de minimis" exemption from TRS registration will be available for certain small, low-risk trusts created after the new rules come into effect. The exemption is not retrospective and will only apply to new trusts created after the rules are in force.

Such trusts will be exempt from TRS registration provided they meet all of the following criteria:

The trust is not liable for any relevant UK taxes (such as income tax, capital gains tax, inheritance tax, or stamp duty land tax).
The trust does not own or have any interest in UK land or real property.
The total value of the trust’s assets does not exceed £10,000.
The trust’s annual income does not exceed £5,000.
The total value of any non-financial assets (such as art, jewellery, or antiques) held by the trust does not exceed £2,000.

5. Liability to Stamp Duty Reserve Tax (SDRT) will no longer trigger registration

Under the previous regime, a trust that became liable to pay SDRT—arising from transactions in UK shares—could be required to register on the TRS, even if it had no other UK tax liabilities or connections. The Government has now announced that SDRT will no longer be considered a "relevant tax" for the purposes of triggering a TRS registration requirement. Again, this change will apply from the date on which the new rules come into force.

Timing

HM Treasury released draft changes to anti-money laundering regulations in September 2025 and began a technical consultation, which closed at the end of the month. The final rules are expected to be implemented in early 2026.

What does this mean for trustees?

The scope of the TRS is expanding: all non-UK express trusts holding UK land—regardless of when the land was acquired—will soon be required to register if the land is still held when the new rules take effect. Nonetheless, in practice, many trusts may already be registered due to other UK tax exposures (for example, inheritance tax anniversary charges, or income tax on the rental income). Therefore, the overall impact of the changes may be less significant than one might think.
Trustees should review any unregistered trusts under management now, to identify any structures that may be affected and consider whether restructuring or early action is advisable before the new rules are implemented. For any trusts that will become registrable, trustees should start preparing to gather the necessary information for TRS registration, including details of the trust, trustees, settlors, beneficiaries, and any other individuals exercising effective control.
TRS data sharing rules will apply to all non-UK express trusts with UK land, even if none of the trustees are UK-resident, increasing the potential for information disclosure to parties with a “legitimate interest".
The proposed updates to the TRS include some positive changes, for example:
- The two-year registration exemption for trusts connected to estates should make the administration of estates involving multiple trusts more straightforward, and provide a longer timeframe for executors and trustees to assess the need for registration and gather the required information. Nonetheless, the two-year deadline should be monitored carefully, as registration will be required if the trust remains in existence beyond this timeframe.
- The introduction of the "de minimis" exemption for small, low-value trusts created after the new rules commence, although care will need to be taken to ensure that all the criteria are met. In particular, trustees should carefully monitor the trust’s assets and income as, if any threshold is exceeded, the trust will become registrable and remain so, even if its value later falls below the limits.
- The removal of SDRT as a "relevant tax", such that liability to SDRT alone will no longer trigger TRS registration.

Summary of changes

Change	Current Position	New Position	Practical Impact
Extension of Registration to Non-UK Trusts with UK Land	Non-UK express trusts only have to register if they acquired UK land on/after 6 Oct 2020 or triggered registration another way.	All non-UK express trusts holding UK land (regardless of acquisition date) must register, if they still hold the land when the new rules take effect.	Trustees of affected trusts must register; consider restructuring or disposals before commencement.
Broader Data Sharing for Non-UK Trusts with UK Land	Only non-UK express trusts with at least one UK-resident trustee were subject to TRS data sharing rules.	All non-UK express trusts with UK land will be subject to data sharing, regardless of trustee residency.	More trust data may be accessible to those with a “legitimate interest” (e.g. investigators).
Harmonised Registration Deadlines for Post-Death Trusts	Co-ownership property trusts and trusts created by deed of variation had to register within 90 days of creation or death; will trusts had a 2-year exemption.	Two-year exemption from registration for co-ownership property trusts, s.34 Trustee Act 1925 trusts, and trusts by deed of variation created on death, aligning with will trusts.	Simplifies compliance and reduces administrative burden for estate-related trusts.
De Minimis Exemption for Small Trusts	No general exemption for small, low-value trusts.	New trusts (created after the rules take effect) are exempt if: no UK tax, no UK land, ≤£10,000 assets, ≤£5,000 annual income, ≤£2,000 non-financial assets.	Small, low-risk trusts created in future may avoid registration; not retrospective.
SDRT No Longer a Relevant Tax for Registration	Liability to Stamp Duty Reserve Tax (SDRT) could trigger TRS registration for some trusts.	SDRT liability alone will not require a trust to register on the TRS.	Fewer non-UK trusts with no other UK links will need to register.