Important AEOI Changes for UK Trusts and Investment Companies: Mandatory Registration by 31 December 2025

The UK's Automatic Exchange of Information (AEOI) regulations were introduced as part of a global drive to crack down on tax evasion. The rules facilitate the annual collection of information by HMRC from ‘Financial Institutions’ (‘FI’s) such as banks and investment brokers so that it can be shared with relevant overseas tax authorities – whether that be the US (under the Foreign Account Tax Compliance Act – ‘FATCA’), or countries who signed up to the OECD’s Common Reporting Standard (‘CRS’). 

Significant updates to the regulations earlier this year now mean that many UK trusts, investment companies, partnerships and other entities must now register with HMRC’s AEOI portal by 31 December 2025. However, the full impact of these changes on private companies and trusts has only recently become clear.  

The new requirements affect a wider group of entities than many may expect. 

What Has Changed? 

In July 2025, the UK amended the International Tax Compliance Regulations to align with updates to CRS by the OECD (‘CRS 2.0’). At the same time the changes introduced mandatory registration requirements for certain entities regardless of whether they have information to report.  

Previously, some trusts and entities classified as Financial Institutions (FIs) did not need to register if they had no reportable accounts, typically because all connected individuals were UK-resident. This exemption has now been removed.  

Who Must Register? 

1. UK Reporting Financial Institutions (RFIs)

Entities must register if they fall within the CRS/FATCA definition of an FI, including: 

• UK Trusts, companies, partnerships or other entities where more than 50% of income derives from financial assets, where 

• Those assets are professionally managed (e.g., by a discretionary fund manager or investment manager). 

2. UK Trustee Documented Trusts (TDTs) 

A TDT is a trust where: 

• A professional or corporate trustee manages the trust, and 

• The trustee agrees to fulfil CRS/FATCA reporting on the trust’s behalf. 

While previously any annual reporting for TDT’s was carried out by the professional trustee, now the Trust must itself register and report in it’s own right. 

For these purposes, financial assets are securities (stocks, shares, bonds, debentures), commodities, swaps, insurance or annuity contracts and interests in partnerships, but do not include direct interests in real property or cash. 

Key Deadline 

**Registration must be completed by 31 December 2025 
(or 31 January of the year after the entity first falls within scope, if later) 

This may be a challenge for many and so there is some relief in that, in recognition that the change has not been widely publicised until very recently, HMRC has indicated that penalties (usually £1,000 for notification failures) will not be issued automatically. They remain enforceable, however, and so it is recommended that any registrations are completed as soon as possible. 

How to Register 

• Registration is completed via HMRC’s AEOI portal at https://www.gov.uk/guidance/register-for-automatic-exchange-of-information using an organisation’s Government Gateway Business Tax account. Trust's will likely need to create a new account. 

• Registration must be in the entity’s name, not the trustees’ (who would previously have been responsible for reporting on Trustee-Documented Trusts. The reporting trustee is listed as the contact.)  

• The registration is a one-off requirement; once registered, the entity remains registered unless it deregisters.  

There is no requirement to submit annual nil returns (normally due by 31 May in relation to the previous calendar year) where an FI or TDT has no reportable accounts, although it may choose to do so.  

All FIs are, however, required to identify and maintain information on the tax residence of ‘Account Holders’ and carry out appropriate due diligence procedures. 

Practical Steps: What Should Trustees and Company Directors Do Now? 

1. Assess whether your trust or company meets the FI or TDT definitions. 
   Entities with investment portfolios, with discretionary fund managers, or corporate trustees are most at risk.  
2. Review your structure and income sources. 
   If more than 50% of income is from investments, registration is likely required unless the entity and its assets are both managed by private individuals.  
3. Prepare the information needed for the AEOI portal. 
   Requirements broadly mirror the Trust Registration Service (TRS) for TDTs.  
4. Review documentation and liaise with brokers. 
   Any newly registered entities need to be confident that they can support the tax status of all beneficial owners to be confident that no reporting will be required for the year to 31/12/26. Any banks or fund managers will also need to be updated on any change of status under AEOI. 

Looking Ahead: Changes from 2026 

From 1 January 2026, further changes come into effect in line with ‘CRS 2.0’: 

• CRS will expand to include reporting under the Cryptoasset Reporting Framework (CARF).  

• enhanced due diligence requirements will apply,  and additional data fields must be reported for the year ended 31 December 2026 (by 31 May 2027) 

How can we help?

These changes significantly expand the scope of AEOI compliance. Many trusts and investment focused entities previously outside the reporting framework are now required to register — even if they do not ultimately need to submit annual reports. 

If you believe your trust, company or partnership may be affected, we recommend reviewing the rules as soon as possible. Our team can assist with classification, registration, and ensuring ongoing compliance.