CRS Reporting: what trustees need to know before the deadline

Now, without much fanfare, the CRS regime has broadened its scope.  Trusts that previously weren’t required to report to HMRC may now need to do so by 31 December 2025.  Going forward, any trust falling within this expanded regime must be reported by 31 January following the calendar year in which it becomes reportable.

The good news?  If the only reason you’re registering is this extension, it’s typically a one-off requirement.  And while the information required, including contact details and tax identification numbers, is not complicated, it does introduce additional administrative responsibility for trustees.  With the deadline approaching, it’s important to act now.

Which trusts are affected?

• Financial Institutions: broadly, these are trusts with a professional trustee or trusts holding financial assets under professional management.  Some may not have needed to register before, particularly if there were no non-UK associated parties.
• Trustee Documented Trusts: these are trusts where a professional trustee has taken responsibility for reporting information on behalf of the trust.  Now, these trusts are expected to register themselves.

Penalties for non-compliance can be significant.  Failing to provide the required information by the deadline could result in an initial penalty of £1,000, with ongoing non-compliance attracting further, potentially daily, penalties.

Similar reporting requirements may also extend to family investment companies, such as those set up to hold financial assets for estate planning purposes.

Trustees should review their trusts now, understand whether they fall within the expanded CRS rules, and, if so, take steps to register in time.  Acting now can save stress and penalties later.

If you would like further clarification or advice, contact our Private Wealth team who can help.