Paraplanners need to be aware of the changes around trust registration, including the impact of Ireland’s Central Register of Beneficial Ownership of Trusts. Kirsten Morgan, Senior Technical Manager at M&G goes jumps into the details in her latest article for Professional Paraplanner.
Changes to the Trust Registration Service (TRS) and the impact of Ireland’s Central Register of Beneficial Ownership of Trusts (CRBOT) mean trust compliance has become a practical issue for advisers, not just trustees.
But trusts remain an essential part of inheritance tax planning and the income tax advantages offshore bonds can bring mean that, for many clients, these benefits will outweigh any extra administration.
Understanding when registration is required is essential to avoid delays, blocked transactions and client detriment.
Trust registration and financial planning contexts
Trust-based planning remains central to financial advice, particularly for estate planning and protection arrangements.
During 2026, further changes to the TRS regime will be made, while CRBOT requirements have the potential for real transactional consequences unless advisers and trustees take pro-active measures.
These regimes affect whether investment bonds can be issued, whether policy transactions can proceed, and whether clients can access funds when needed.
The Trust Registration Service: where we are now
Since October 2020, most UK express trusts have been required to register on the TRS regardless of whether they have a UK tax liability.
This expanded role positioned the TRS as a beneficial ownership register within the UK’s anti‑money laundering framework rather than a purely tax-driven system.
This extension brought many commonly used arrangements into scope, including gift trusts, loan trusts, discounted gift plans and flexible reversionary interest trusts, even where the trust itself has no immediate tax consequences.
Further TRS changes are coming
On 26 March 2026, HM Treasury laid the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 before Parliament.
This draft regulation will broaden TRS coverage in specific areas, while introducing limited simplifications to reduce unnecessary administration for some trusts.
The draft regulations are expected to become law between May – July 2026.
TRS as a gateway to financial transactions
HMRC increasingly treats TRS registration as a gateway requirement rather than a standalone compliance obligation.
In practice, many investment and life offices cannot meet their regulatory requirements and process bond transactions, assignments or surrenders unless TRS registration can be confirmed.
For advice professionals, failure to address TRS status early can result in stalled transactions and frustrated clients at critical moments.
Targeted TRS simplifications
Alongside expansion, some provisions are being made more consistent. Registration deadlines will be aligned across trusts arising on death, providing a consistent two‑year grace period for trusts created under wills, deeds of variation and certain co‑ownership arrangements.
A de minimis exemption will also apply to newly created low‑value trusts. These, broadly speaking, will be those with:
- assets of less than £2,000, and
- income of less than £5,000, and
- has not held more than £10,000 cumulatively over the lifetime of the trust.
This exemption will only apply if the settlor has set up no other trusts in their lifetime.
However, most trusts used in mainstream financial planning are likely to remain registerable, meaning the practical impact of this exemption will be limited for advice professionals.
It may be of use where a client plans to set up a pilot trust, for example a Bypass Trust, with a nominal amount after these regulations come into effect.
However, given that the trust will become registrable when the lump sum is paid in, and the potential interaction with other trust planning, for some clients it may be simpler to register the trust when created.
The Irish CRBOT: Why it matters for UK planners
Ireland’s Central Register of Beneficial Ownership of Trusts applies not only to Irish trusts, but also to UK trusts with Irish connections.
This includes trusts that hold Irish property or have an ongoing business relationship with an Irish‑regulated entity.
The most common trigger is the holding of an Irish‑issued offshore investment bond, which constitutes an ongoing business relationship and brings the trust within CRBOT scope.
The current CRBOT position
Since 5th March 2025, UK trustees have been required to register qualifying trusts on CRBOT. Registration on the UK TRS does not remove this obligation.
In practice, transactions involving Irish‑issued products are increasingly delayed until CRBOT registration is completed.
This mirrors the TRS experience, reinforcing the role of beneficial ownership registers as effective transaction gateways.
Where trusts hold Irish offshore bonds, dual registration requirements are now a routine part of advice and ongoing servicing.
Dual registration is now standard for UK trusts holding Irish bonds
For many trust-based financial planning structures, particularly those involving offshore bonds, registration on both the TRS and the CRBOT is unavoidable.
One regime does not substitute for the other, and each must be satisfied independently.
If a trust has been registered on the TRS, then the trustees will have around 80-90% of the information needed to register on the CRBOT.
However, there are some key differences that can cause issues if they are not fully understood.
- Exemptions for the UK TRS do not apply to the Irish CRBOT.
- HMRC took the decision to exclude certain trust arrangements it considered low risk from the requirement to register on the TRS for anti-money laundering purposes. These include personal injury trusts, disabled trusts and pensions trusts.
- These exemptions do not exist in Irish legislation.
- More beneficiary information is required for the Irish CRBOT than the UK TRS
- Trustees will need to add the extent of any known beneficial interest to the CRBOT, for example, a life tenant’s right to income
- The addresses of these beneficiaries will also be required.
- While individuals within classes of beneficiaries do not need to be named at outset, if it’s likely that trustees will pay, assign or appoint benefits to them in future, it may save time to give their details and ID at registration.
- ID for individuals will need to be uploaded
- Identification documentation (for example, a passport) for the settlor(s), trustees and any named beneficiaries will need to be uploaded.
Conclusion
Trust registration has moved from the margins to the centre of trust‑based financial planning.
Financial advice professionals who embed TRS and CRBOT awareness into advice processes will be best placed to deliver timely, interruption‑free outcomes for clients in an increasingly transparent regulatory environment.
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