The rules around Automatic Exchange of Information (AEOI) have shifted – and if you’re a trustee or company director, they’re now firmly on your radar.
HMRC has introduced new mandatory AEOI registration requirements under the UK’s CRS (Common Reporting Standard) and FATCA framework. Certain trusts and companies must now register for HMRC’s AEOI service, even where there’s no reportable information to submit.
For many existing arrangements, the deadline to register was 31 December 2025, and HMRC expects trustees and directors to ensure their obligations have been met.
The rules are technical and entity specific, depending on matters such as how a trust or company is managed and the nature of its income.
Below, you’ll find everything you need to know.
WHO NEEDS TO REGISTER FOR AEIO?
Under CRS, a trust or company must register with HMRC if it’s treated as a:
- Reporting Financial Institution (RFI), or
- Trustee-Documented Trust (TDT)
A trust or company is a Reporting Financial Institution where:
- 50% or more of its income comes from investments, and
- Its assets are professionally managed on a discretionary fund management basis.
A trust is a Trustee-Documented Trust where:
- 50% or more of the trust’s income arises from investments, and
- There is a trustee that is itself a Reporting Financial Institution (this is broadly the case where there is a professional corporate trustee).
These rules can apply to a wide range of structures – including bare trusts, family investment arrangements and companies holding investment portfolios. It’s not the label of the structure that matters, but how the assets are managed.
KEY AEOI REGISTRATION DEADLINES
HMRC’s stated deadlines for registration are:
- 31 December 2025, or
- If later, 31 January following the calendar year in which the trust first becomes a Reporting Financial Institution or Trustee-Documented Trust.
If you fall into scope and haven’t registered yet, this should now be treated as a priority.
WHO CARRIES THE RESPONSIBILITY?
Responsibility for compliance rests with the trustees or directors who are required to ensure that registration is completed where necessary.
WHAT SHOULD YOU DO NOW?
To stay compliant with HMRC’s AEOI registration requirements:
- Consider whether your trust or company may fall within scope of the AEOI rules;
- Contact your fund manager to establish if registration is required or has already been completed;
- If not, ensure registration is completed as soon as possible where required (registration is completed online via a Government Gateway).
AEOI: WHAT YOU’LL NEED TO REGISTER
HMRC guidance and the registration link can be found here:
https://www.gov.uk/guidance/register-for-automatic-exchange-of-information
Step #1 – You’ll need to create a new Government Gateway ID and password (you can’t use the one set up for the Trust Registration Service). Ensure you confirm you are an organisation when setting this up too.
Step #2 – When you arrive at the page asking which Tax account you want, click on “Other taxes.” This takes you to another screen where you can select the “Automatic Exchange Of Information” option. Ensure you say “no” when asked if you have registered for AEOI before.
Step #3 – Enter your contact name and address and then you can add the trust by clicking on “Add reporting financial institution.”
The details HMRC require for the reporting financial institution include:
- Trust/company name
- Email address;
- Where applicable, a FATCA GIIN (this is a US tax reference number, if no GIIN is held use 000000.00000.LE.000).
- The trust’s/company’s UTR (if the trust has no UTR but instead a URN then you should tick the box that says no tax identification number); and
- The Filer category – PFFI
If you require support from HMRC, the AEOI helpline number is 03000 576 748.
PENALTIES: WHAT HAPPENS IF YOU DON’T REGISTER?
HMRC has confirmed that while penalties won’t be issued automatically, late registration can still result in:
- An initial penalty of up to £1,000, and
- Daily penalties if noncompliance continues after a notice is issued.
Importantly, HMRC has acknowledged that awareness of the new rules has been low – so if you register as soon as possible and have a reasonable excuse, penalties may not apply.
Still, this isn’t something to sit on. If you fall within scope, act now.
NEED HELP WITH AEOI? LET’S TALK
While the compliance responsibility sits with trustees and directors, our team is here to support you.
If you’re unsure whether your structure meets the AEOI registration criteria – or you’d like guidance on navigating the CRS/FATCA rules – get in touch and we’ll help you get it sorted.
