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Trustees should consider whether their trust or designated account needs to register with HMRC under the Automatic Exchange of Information (AEOI) rules.
HMRC has clarified that, in general, where a trust holds a General Investment Account and invests in a model portfolio, such as WealthSelect, or a discretionary managed portfolio service, the trustees will need to register the trust for AEOI purposes.
This guidance explains which arrangements may be affected, what HMRC has confirmed, and how trustees can register if they need to.
At a glance
- Trustees remain responsible for determining whether AEOI registration is needed.
- The requirement is separate from any obligation to register with HMRC’s Trust Registration Service (TRS).
- In general, non-professional trustees holding a Collective Investment Account or General Investment Account and investing into an MPS or discretionary managed portfolio service may need to register.
- HMRC has confirmed that non-professional trustees holding a Collective Investment Bond do not need to register for AEOI in this scenario.
What has changed?
Following the introduction of The International Tax Compliance (Amendment) Regulations 2025, UK reporting financial institutions and UK trustee-documented trusts have a one-off requirement to provide information to HMRC through the AEOI portal.
Registration deadlines
The registration deadline was 31 December 2025 for existing trusts, or 31 January following the calendar year in which the entity becomes registerable, if later.
Where trustees have a trust or designated account that meets the criteria but has not yet been registered, trustees should register as soon as possible. There is a penalty regime for late filing, but HMRC has previously confirmed to industry bodies that late registration penalties will not apply where there is a reasonable excuse for the delay. If support is needed, HMRC can be contacted at enquiries.aeoi@hmrc.gov.uk.
When is a trust or other entity a financial institution?
For AEOI purposes, trustees and other entities must determine whether they meet the criteria to be treated as a financial institution. The rules are complex, and detailed guidance is available in HMRC’s International Exchange of Information Manual here. However, the key test for most trusts is the ‘investment entity’ test. Broadly, this considers whether 50% or more of the trust’s income is derived from investments and whether the trust is managed by a financial institution. Where both conditions are met, the trust will generally be a reporting financial institution and will need to register with HMRC.
These rules may apply to bare trusts and irrevocable designated accounts available through the Quilter Investment Platform.
What does this mean in practice?
It remains the trustees’ responsibility to determine whether a trust or designated account needs to register with HMRC for AEOI purposes. However, the following table reflects recent clarification we have received from HMRC.
|
Scenario |
Is AEOI registration required? |
Why? |
|
Non-professional trustees holding a Collective Investment Bond, including where a model portfolio is used as a linked asset. |
No. |
HMRC has agreed that the trust assets are not regarded as being managed by the investment manager because the trustees own the insurance contract only. |
|
Non-professional trustees holding a Collective Investment Account or General Investment Account and investing into an MPS, such as WealthSelect, or a discretionary managed portfolio service. |
Yes, in general. |
HMRC has confirmed that this arrangement meets the “managed by” test because a discretionary investment manager has discretion to manage the trust assets. |
Non-professional trustees holding a Collective Investment Bond
No registration through the HMRC AEOI portal is required in this scenario. This is separate from any registration requirement under the Trust Registration Service (TRS).
HMRC has agreed that where a model portfolio is used as a linked asset within a Collective Investment Bond, this does not cause the trust to be treated as professionally managed, even where the model portfolio is operated under a discretionary mandate. This is because, under the bond structure, the linked assets or units are legally and beneficially owned by the life company rather than the trustees. The trustees own the insurance contract only, so the trust assets are not regarded as being ‘managed by’ the investment manager.
Non-professional trustees holding a Collective Investment Account
Non-professional trustees who invest through a Collective Investment Account into an MPS, such as WealthSelect, will need to register the trust or designated account through the HMRC AEOI portal.
HMRC has confirmed that where a model portfolio operated under a discretionary mandate is used with a Collective Investment Account, the arrangement meets the ‘managed by’ test.
We consider this to be a cautious approach by HMRC and challenged it on the basis that the trustees do not enter into a direct agreement with, or have a direct relationship with, the discretionary investment manager. In practice, the arrangement operates in a similar way to a managed fund.
However, HMRC has confirmed that the key point is that a discretionary investment manager has been appointed and has discretion to manage the trust assets. HMRC does not require a direct agreement between the trustees and the discretionary investment manager.
How do trustees register for AEOI purposes?
Trustees can register through HMRC’s AEOI portal. The registration is completed once and covers both CRS and FATCA.
Where a trust falls within the scope of CRS, FATCA or both regimes, there is no requirement to tell HMRC which regime applies.
Registration is a one-off requirement. Once registered for the AEOI service, the trust will remain registered for future years unless it deregisters.
If a trust registers for the AEOI service but has no reportable accounts, it does not need to submit a nil return, although it may choose to do so.
Each entity treated as a financial institution should register for AEOI if it is either:
- a reporting financial institution, whether or not there is any information to report; or
- a trustee-documented trust, whether or not the trustee has any information to report.
HMRC guidance on AEOI registration is available here:
What should advisers do?
- Review whether any client trust or designated account arrangements may be affected.
- Check whether the arrangement involves a General Investment Account or Collective Investment Account and an MPS or discretionary managed portfolio service.
- Speak to trustees about whether AEOI registration is needed.
- Direct trustees to HMRC’s AEOI portal if they need to register.