How to Manage Your Trust's Details with HMRC

Managing a trust involves more than just setting it up — trustees have ongoing legal responsibilities to keep trust information accurate and up to date with HMRC. The Trust Registration Service is the online tool you'll use to update trustee, beneficiary and settlor details, declare information is current, and close a trust when needed. Understanding what you can update yourself and what requires direct contact with HMRC will help you fulfil your obligations and avoid penalties.

Who needs to use the Trust Registration Service

Most UK express trusts must register with HMRC. An express trust is one created deliberately by a settlor (the person who establishes the trust), usually through a written deed or declaration of trust. Once registered, trustees must use the Trust Registration Service online to manage the trust's details.

The specific information you'll need to provide depends on when you originally registered the trust, as HMRC has introduced additional requirements over time.

What you need to do if you registered before May 2021

If you registered your trust before 4 May 2021, the first time you access the service you'll need to provide some additional information that wasn't required during the original registration process.

You must tell HMRC:

• Whether the trust is an express trust
• Whether the trust pays tax

Once you've given this information, you'll need to sign out of the service completely before you can update any other details about the trust.

When you return to make changes, you'll also need to confirm whether:

• A non-UK trust has a business relationship in the UK
• The trust has purchased any UK land or property
• The trust has a controlling interest in a company outside the EU, Iceland, Liechtenstein, Norway or Switzerland

This information became standard for all trusts registered after 4 May 2021.

What you need to do if you registered before October 2022

If you registered your trust before 17 October 2022, you'll need to say whether it's a Schedule 3A trust when you next access the service. Schedule 3A trusts are also called 'excluded express trusts'.

Your trust is a Schedule 3A trust if it is:

• A statutory trust created by a court order or by law (such as a trust created during divorce proceedings)
• Holding money or assets of a UK registered pension scheme
• Holding life insurance policies that only pay out on death, illness or disability
• For a registered UK charity
• Set up to open a bank account for a child
• A 'will trust' set up on death that takes assets from the estate and closes within two years
• A 'pilot trust' with less than £100 set up before 6 October 2020
• A co-ownership trust holding property or assets owned jointly by two or more people as 'tenants in common'
• Related to financial markets, professional services, or client money holdings
• For capital markets transactions
• Created to enable commercial transactions
• Related to registration of assets (holding legal title temporarily)
• Set up for legislative requirements (such as holding compensation for personal injury or for vulnerable beneficiaries)
• Set up by government or other UK public authority

This became part of the standard registration process for all trusts registered after 17 October 2022.

What trust details you can update online

You must update any changes to the trust within 90 days. You'll need to complete all changes in one session — you cannot save partly completed details and return later, so gather all necessary information before you start.

For the lead trustee, you can update address, telephone number, email address, country of residence and country of nationality. If the lead trustee is an organisation, you can update the organisation name, Unique Taxpayer Reference, address, telephone number, email address, country of residence and UK registered company status.

For other trustees, you can update name, date of birth, country of residence, country of nationality, mental capacity at registration, National Insurance number (for UK citizens), address, and passport details and address (for non-UK citizens).

For beneficiaries, you can update details for individuals, companies, trusts, charities, large beneficiaries, other types and unidentified classes.

For settlors, you can update name, address (except for deceased settlors), date of birth, date of death, last known country of residence (except deceased settlors), last known country of nationality (except deceased settlors) and mental capacity status. You'll also need their National Insurance number (if a UK citizen) or passport details and address (if not).

For protectors or other individuals, you can update name, date of birth, National Insurance number and address (UK citizens), passport details and address (non-UK citizens), country of residence, country of nationality and mental capacity status.

For controlling interests in non-EEA companies, you can update the company name, address, governing country and start date of the trust's ownership or controlling interest.

Important warning: If you remove all trustees, settlors, named beneficiaries or all classes of beneficiaries, the trust will be treated as closed and you may not be able to access the service later. If someone is taking over these roles, wait until you have their details before removing previous information.

What you cannot update online

You must write to HMRC to:

• Change the trust start date
• Change the name of the trust
• Remove a settlor
• Change lead trustee information including name, date of birth, National Insurance number or passport details

You also cannot change asset details through the Trust Registration Service. To update asset details, use either Self Assessment online or the Trust and Estate Tax Return (form SA900).

Annual declaration requirements

If your trust is liable to tax in any tax year, you must declare on the trust register that the details of all persons associated with the trust are accurate and up to date. You must do this even if you haven't made any changes.

If the trust is liable to Income Tax or Capital Gains Tax, you'll also need to confirm on the trust's Self Assessment return (SA900) that you've either updated the details on the trust register or confirmed there have been no changes.

If the trust is not liable to tax, you do not need to make an annual declaration.

Records you must keep

Trustees must maintain comprehensive records. At minimum, you should keep:

• Bank statements for current and deposit accounts
• Confirmation of interest paid into bank or building society accounts
• National savings bonds or certificates
• Certificates issued by life assurance companies
• Dividend vouchers from companies and unit trusts
• Stockbroker reports and records of dividends
• Details of expenses paid by trustees
• Details of all taxes paid by the trust
• Records of income payments to beneficiaries (for discretionary trusts)

For express trusts, you must also keep records of:

• The full name of the trust and the date it was created
• The country where the trust is resident for tax purposes
• Where the trust is administered
• A contact address for the trustees
• Full name and address of any paid advisers providing legal, financial or tax advice

For all settlors, trustees and beneficiaries, keep:

• Their role (settlor, trustee or beneficiary)
• Full name
• National Insurance number or Unique Taxpayer Reference
• Date of birth
• Postal address (or passport/ID card details if the address is not in the UK)

You should also keep records of important trustee decisions, including minutes of meetings, deeds of appointment and decisions affecting distribution of capital or income.

How long to keep records

The retention period depends on whether the trust has business income.

If the trust has business income: Keep records for five years after the filing deadline of 31 January. For example, if you submit a return for tax year 2025 to 2026 by 31 January 2027, you must keep records until 31 January 2032.

If the trust has no business income: Keep records for one year after the filing deadline of 31 January. For example, if you submit a return for tax year 2025 to 2026 by 31 January 2027, you must keep records until 31 January 2028.

If you submit a return late, keep records for either 15 months after the date you sent the return or five years after the deadline (for business records), whichever is later.

If HMRC starts a check, you must keep records until they tell you the check is finished. Once the retention period has passed, you must delete records unless you're legally obliged to keep them, a trustee reasonably believes they must be kept for legal purposes, or the person whose information you hold has given consent.

Accessing the trust as lead trustee

If you're the trustee who registered the trust, you'll need to answer security questions about people associated with the trust before you can view or amend details. Your answers must match the information entered at registration or when the trust's details were last updated.

Use the same credentials you used to register the trust to access the service.

Closing a trust

You must use the online Trust Registration Service to close a trust when it comes to an end.

Sources

• Manage your trust's details
• Records to keep for trusts

This article provides general guidance based on current HMRC rules. For advice specific to your situation, speak to your accountant.