Changes to AEOI FATCA and CRS registration for certain trusts
Private Client analysis: The International Tax Compliance (Amendment) Regulations 2025, SI 2025/740 updated the UK’s rules for Automatic Exchange of Information (AEOI) under the US Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS), introducing mandatory HMRC registration for certain financial institutions (as well as expanding self-certification and compliance obligations). Existing in-scope financial institutions had to register with HMRC by 31 December 2025, with the deadline for registration for the 2026 reporting year onwards set for 31 January following the first calendar year in which the financial institution comes within scope. With certain trusts caught by the new registration requirement, trustees and their advisers should consider whether their trusts must now register with HMRC. Written by Elinor Boote, senior associate, Caroline Belam, knowledge development lawyer and Ciara John, knowledge paralegal at Charles Russell Speechlys.