Registration required for Reporting Financial Institutions and Trustee-Documented Trusts by 31 December

A new registration requirement means that some trusts and other entities will need to register for HMRC’s AEOI service by 31 December 2025.

The new requirement 

In July 2025 the International Tax Compliance (Amendment) Regulations 2025 introduced a new mandatory registration requirement for entities falling within the definition of Reporting Financial Institution (RFI) or Trustee-Documented Trust (TDT), for the purposes of either or both of Common Reporting Standard (CRS) and US Foreign Account Tax Compliance Act (FATCA).

All RFIs and TDTs must register for HMRC’s automatic exchange of information (AEOI) service by the later of 31 December 2025 or 31 January following the calendar year in which the entity first falls within the definition of RFI or TDT.

RFIs that are already registered for AEOI do not need to take any further action. 

HMRC guidance and registration portal

HMRC has added some guidance on the new requirement to its International Exchange of Information Manual. Key points include:

• When registering a Trustee-Documented Trust for AEOI, the TDT should be shown as the Reporting Financial Institution, not the trustee. The reporting trustee should be named as a contact.
• The registration is a single registration for AEOI covering both CRS and FATCA. Where an entity is within the scope of either CRS or FATCA but not both, there is no requirement to notify HMRC which of the regimes the entity falls within.
• The registration is a one-off requirement. Once an entity has registered for the AEOI service it will remain registered for subsequent years unless it deregisters.
• If an entity registers for the AEOI service and has no reportable accounts, there is no obligation to submit a nil return, although the entity may choose to do so.
• Financial Institutions that are taken out of scope by CRS2.0, for example charities meeting the criteria to be Qualified Non-Profit Entities may deregister from HMRC’s AEOI service from 1 January 2026. HMRC will accept that any such non-profit organisation that has not registered with HMRC’s AEOI service because it has never had Reportable Accounts is not required to register by 31 December 2025.

Entities should register via HMRC’s AEOI portal. We understand that once a registration has been filed, it isn’t possible to file another for 24 hours, to allow for processing – but agents who need to file multiple registrations can load up to 250 trusts in one go.

STEP has also published some guidance on the new registration requirement. 

Problems meeting the deadline?

There are penalties for failure to register. However, we understand that penalties will not be automatically charged for late registrations. HMRC is aware that December is part of the busy self assessment season.

If agents are having difficulties meeting the deadline, and consider that the circumstances constitute a reasonable excuse, they should contact enquiries.aeoi@hmrc.gov.uk to explain why. RFIs and TDTs should make best efforts to register as soon as reasonably possible after the deadline.

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