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Trust Registration Deadline Set For Trusts HMRC Cannot Yet Register

ended 09. August 2026

A registration duty now has a date on it, and the register is closed to the trustees who have to meet it. On 7 August 2026 HMRC rewrote a set of pages across its Trust Registration Service Manual to reflect SI 2026/621, which amends the Money Laundering Regulations 2017. One of those pages, TRSM22010, now carries a note reading: “As of 30th June 2026, non-UK trusts holding UK land acquired pre-6 October 2020, and still held that land on the 30th June 2026 are required to register on TRS; trustees in this position must register by 1 Sep 2027.” That is a new class of trust pulled onto the register. Not UK trusts, and not land bought since October 2020, but non-UK trusts that held UK land acquired before 6 October 2020 and still held that land on 30 June 2026.

The catch is printed on the manual's own front page. A banner there reads: “Non-UK trusts that acquired UK property before 6 October 2020 are not currently able to register due to changes to the IT system. We will release an update in due course.” TRSM22010 says the same thing in its own words, that the IT is being updated to support these additional registrations and that further guidance on when trustees in this position can commence registration will be issued in due course. The 1 September 2027 date is not HMRC's to move: it sits in regulation 45ZA of the 2017 Regulations as amended. The outage is HMRC's, the duty is the trustees'. Every week the service stays shut is a week off whatever time trustees eventually get to use it.

The same day brought quieter changes running the other way. A new page, TRSM23170, sets out a de minimis exclusion that takes some small UK trusts off the register. Stamp Duty Reserve Tax has been removed as a tax that triggers registration, new registration deadlines apply to certain property trusts, and HMRC's change note records TRSM60010 as amended to remove the exemption for non-UK trusts from Trust Data Requests. The person at the sharp end is rarely an offshore magnate. It is often a family arrangement holding one UK flat or a strip of land bought years ago, with a UK-resident relative as trustee, who now carries a legal duty and no way to discharge it.

  1. The regulations set a registration deadline of 1 September 2027 for these trusts, while HMRC's own manual says they are not currently able to register. Is it acceptable for the clock to run before the route to comply exists?
  2. The duty sits on the trustees and the delay sits with HMRC. Who is hit hardest by that gap, and is it fair on a family trust with one UK property and no in-house adviser?
  3. What should trustees and their advisers be doing between now and 1 September 2027, and should the deadline instead run from the day the service reopens? Do you have a client whose plans this would change? If so, please give as much colour and detail as possible.

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Editor
Mark Alexander
Founder at Property118.com
It seems difficult to justify a statutory compliance clock running while HMRC’s own system does not yet allow the affected trustees to comply. Parliament may have created the obligation, but HMRC controls the practical route to registration. The fair solution would be for HMRC to confirm now that nobody will be penalised or otherwise disadvantaged because its IT system was not ready, and that trustees will have a reasonable period to register once the service becomes available. That matters particularly for small family trusts without professional advisers constantly monitoring regulatory changes. Taxpayers are expected to meet HMRC deadlines, often with penalties for failing to do so. It is reasonable to expect the same degree of administrative responsibility from HMRC when the obstacle to compliance sits with HMRC itself.