The Trust Registration Service - update

Mar 15, 2021

The requirement to register a trust using the Trust Registration Service is being extended as part of the UK’s implementation of the Fifth Money Laundering Directive. HMRC has now published an overview of the changes including which further trusts will need to register by 10 March 2022. We have also been advised by HMRC that updates to the trust registration service cannot be saved and returned to at a later date.

HMRC’s message on this reads as follows:-

“Unlike the Registration element of the service, this is not a feature that we will be adding to the service when an update is required to a Trust record. Registration of a Trust involves providing a substantial amount of information to HMRC and there was a clear user need that agents/lead Trustees required a time period to be able to:

  • view the service to understand what information was required;
  • contact other people, or organisations involved in the trust, to ascertain information required by the register; and
  • not lose the information input while doing the above.

Throughout user research, we did not identify a user need that highlighted the “save and return” feature was required when updating the Trusts record.  The information captured as part of the registration is available to view/download in PDF format as part of the registration, or upon re-entry to the service to update the Trust record. This provides the opportunity for an Agent/Lead Trustee to view the information submitted and determine which information, if any, needs to be amended. In addition, research highlighted that when changes were to be made to a Trust record, they would be minimal and therefore would be done in one session. 

The user need HMRC must support is for agents/lead trustees to be able to notify HMRC that there has either been no change, a change or to close the trust, and this need has been met. 

Whilst we recognise that some agents may have internal processes to handle the updating of a trust’s details, HMRC services are not designed to support those processes since they may be different for each user.”