Helping you prosper
Following the blog by Tracey Moore and James Kemp in January - What charities need to know about the new AEOI registration requirements - HMRC’s Automatic Exchange of Information (AEOI) registration is now mandatory for many trusts and entities that fall within the definition of UK reporting financial institutions or UK trustee-documented trusts.
Although the rules are aimed primarily at trusts, the scope is much wider and can include companies such as family investment companies, employee ownership trusts and employee benefit trusts.
Which trusts are now likely to need to register?
Under HMRC’s guidance, the following structures are most likely to fall within scope:
Financial institutions
A trust will be classified as a financial institution if more than 50% of its income is derived from financial assets, such as an investment portfolio, and the assets are managed by a fund manager under a discretionary mandate.
Trustee-documented trusts
These are trusts that are professionally managed by a financial institution. In these cases, the trustee carries out the due diligence and reporting obligations on behalf of the trust.
It is important to note that AEOI registration is separate from, and in addition to, the Trust Registration Service. Being registered on TRS does not remove the requirement to register under AEOI.
Deadlines and penalties
The registration deadline passed on 31 December 2025. HMRC has confirmed that no extension will be granted. Penalties for non-compliance can be significant, starting at up to £1,000 for late registration and potentially increasing by £300 per day if the failure continues after the initial penalty notice.
HMRC has stated that any financial institutions or trustee-documented trusts must register as soon as possible. Late registration penalties may be waived if you can demonstrate a reasonable excuse for the delay, but this will be assessed on a case-by-case basis.
How to register
Registration must be completed through HMRC’s dedicated AEOI portal: Register for Automatic Exchange of Information
The process requires trustees to confirm the trust’s classification, provide key identifying information and ensure ongoing compliance with HMRC’s annual reporting obligations. Given the technical nature of the rules, many organisations are seeking support to interpret the criteria correctly and avoid penalties.
The next step
If you are unsure whether your trust, company structure or investment vehicle requires AEOI registration, or if you need assistance completing the process, please get in touch with Brian Carey or Louise Harding or speak to your usual UHY tax adviser for further guidance.
