HMRC Confirms No Extension for End-of-Year Trust Registration Deadline — What Trustees Need to Know

Trustees and their advisors are facing a crucial compliance deadline: 31 December 2025. In a recent announcement, HM Revenue & Customs (HMRC) confirmed it will not extend this year’s deadline for certain trusts to register under new reporting obligations — but it will consider waiving penalties in limited circumstances.

New Compliance Requirements for Trustee-Documented Trusts

The deadline relates to a new registration obligation introduced in 2025 under amendments to the automatic exchange of information (AEOI) regulations, which include the Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA). 

Under these rules, certain trusts — including trustee-documented trusts (TDTs) and other entities that qualify as reporting financial institutions — must register with HMRC’s AEOI service by 31 December 2025 (or 31 January of the year following the calendar year in which they first fall within scope). This is a one-off requirement rather than an ongoing annual filing.

Why a Deadline Matters Now

Historically, trust registration obligations in the UK have focused on the Trust Registration Service (TRS), which requires trustees to register many UK express trusts and certain overseas trusts to meet anti-money-laundering and tax transparency requirements. GOV.UK

The 2025 changes, however, expand this compliance regime to include reporting obligations even for trusts that do not have internationally reportable accounts — meaning trustees must register trusts simply because they fall within the definition of a reporting financial institution or TDT, not because there is taxable income or an international account to disclose.

HMRC’s Position on the 2025 Deadline

Professional bodies representing trustees and advisers had requested that HMRC extend the 31 December deadline to give practitioners more time to assess and complete registrations. However, HMRC declined to grant an extension, citing the international nature of these reporting obligations as a key factor in maintaining the timetable.

Reasonable Excuses and Penalty Relief

While HMRC has confirmed that the deadline stands, there is a key concession for trustees and agents:

• Late penalties will not be issued automatically for registrations submitted after the deadline.

• HMRC will consider whether a trust’s agent can demonstrate a reasonable excuse for any delay (for example, difficulties in gathering required information before 31 December).

  
  

This approach mirrors broader HMRC practice in other compliance areas — late filing penalties can be waived where taxpayers or their agents can show they took reasonable steps to comply.

What Trustees Should Do Right Now

With only a short window before the deadline, trustees and their professional advisers should take several practical steps:

1. Determine whether the trust meets the definition of a reporting financial institution or trustee-documented trust under the CRS/FATCA rules.

2. Register trusts with HMRC’s AEOI service if required by 31 December 2025 (or as soon as possible afterward). STEP

3. Gather all necessary self-certification documentation from trustees, settlors, and beneficiaries to support registration and demonstrate reasonable excuse, if needed. Johnston Carmichael

4. Document compliance efforts thoroughly — this can be critical if HMRC later reviews a late filing and evaluates whether a reasonable excuse exists.

   
   

Why This Matters for Estate and Trust Planning

Failure to register a trust that falls within these new obligations can expose trustees to penalties and compliance risk. Even with HMRC’s concession on reasonable excuses, proactive registration protects trustees and beneficiaries by:

• Ensuring regulatory compliance before potential enforcement

• Reducing risk of penalties if registration is completed shortly after the deadline

• Demonstrating robust governance and reporting standards

• Avoiding complications that arise when trusts are identified late in HMRC’s risk review process

Given the short timeframe and evolving nature of UK trust reporting requirements, trustees should act now rather than wait. Getting ahead of this compliance deadline will help preserve trust integrity and protect trustees from future regulatory scrutiny.

Source: STEP Industry News, “HMRC will not extend end-of-year trust registration deadline, but will accept ‘reasonable excuses’,” 18 December 2025.