UK Trust Registration Service (TRS) Set for Major Overhaul in June/July 2026: Five Key Reforms You Need to Know Now

The UK’s anti-money laundering regime is undergoing targeted but significant updates with the Money Laundering and Terrorist Financing (Amendment) Regulations 2026.

• Was laid before Parliament on 25 March 2026 and
• Is expected to come into force in late June or early July 2026.

While much of the focus has been on customer due diligence and high-risk jurisdictions, the reforms to the Trust Registration Service (TRS) in Part 5 and Schedule 3A of the Money Laundering Regulations 2017 are particularly important for trustees, solicitors, accountants, and TCSPs.

• These changes aim to
• Close transparency gaps (especially around older non-UK trusts owning UK land)
• While introducing proportionate relief for low-risk structures.
• The result is
• A more targeted regime that reduces unnecessary administration without compromising beneficial ownership transparency.
• These TRS reforms demonstrate HM Treasury’s continued commitment to
• Arisk-based, proportionate AML regime,
• Closing genuine gaps
• While removing unnecessary red tape.

Trustees and advisers who act early will avoid last-minute scrambles when the changes take effect this summer.

• The full draft Statutory Instrument and Explanatory Memorandum are available on legislation.gov.uk [SEE SOURCES BELOW] and
• Professional bodies and firms such as the CLC, STEP, and leading law firms have already begun issuing detailed guidance.

Here are the five specific TRS reforms and exactly what they mean in practice.

1. Registration extended to certain non-UK express trusts that hold UK land

• Non-UK express trusts that acquired an interest in UK land or property before 6 October 2020 and still hold that interest will now be required to register on the TRS (subject to any applicable exemptions).
• Previously, only non-UK trusts acquiring UK land on or after 6 October 2020 had to register. This created a known reporting gap for older structures.
• Now, the rules are backdated for any trust that continues to own UK real estate when the regulations take effect. Trustees of these legacy structures must register and provide beneficial ownership information.

• Practical impact:
• Many non-UK family trusts, offshore structures, and investment vehicles that have quietly held UK property for years will suddenly fall into scope. Lead trustees should begin portfolio reviews immediately.

2. New de minimis exemption for low-value, low-risk trusts

• A brand-new de minimis exemption is being introduced for certain low-value, low-risk non-taxable trusts.
• These trusts will no longer need to register (or can deregister if already on the register).
• Key criteria (broadly):
• No UK tax liabilities, no UK land, total assets below a low threshold (expected around £10,000), modest income, and primarily non-financial assets.
• The exact monetary limits will be set out in guidance, but the policy intent is clear — small, simple, low-risk trusts are being taken out of scope.
• Recent drafting improvements:
• Exempt trusts no longer count towards the de minimis limit, allowing settlors to maintain multiple low-risk structures.
• The exemption now applies to existing trusts, enabling deregistration of qualifying trusts already on the register.
• Practical impact:
• This is a welcome burden reduction for many smaller family or purpose trusts. Trustees of low-value structures should assess eligibility as soon as the final criteria are confirmed.

3. Two-year exemption for trusts arising on death is widened

• The existing two-year registration exemption for trusts created on the death of a settlor (or similar death-related events) is being expanded to cover additional categories of trusts arising from estates.
• Practical impact:
• This gives executors and trustees more breathing room when dealing with probate and estate administration.
• It reduces the rush to register during what is often a complex and emotionally charged period, aligning the rules more closely with real-world estate timelines.

4. Scottish survivorship destination trusts are exempted

• A targeted new exemption has been added for Scottish survivorship destination trusts (common in Scottish property law, where title passes automatically to a surviving joint owner).
• Practical impact:
• These structures, which were previously caught by the broad TRS rules, are now fully exempt. This removes an unnecessary compliance burden specific to Scottish conveyancing and estate planning.

5. Stamp Duty Reserve Tax removed as a sole trigger for registration

• Stamp Duty Reserve Tax (SDRT) will no longer, by itself, make a trust a “taxable trust” that must register on the TRS.
• Previously,
• Even a one-off SDRT liability could trigger full registration and ongoing obligations.
• Now,
• SDRT is removed from the list of “relevant taxes” that automatically require registration.
• Practical impact:
• This prevents minor or one-time tax events from pulling low-risk trusts into the full TRS regime. It is a sensible de-cluttering of the rules.

What this means for firms and trustees

• These changes are evolutionary rather than revolutionary, but they have real compliance implications:
• Increased scope for older non-UK land-holding trusts → more registrations.
• Decreased burden for low-risk, low-value, Scottish, and death-related trusts → fewer registrations and easier deregistration.
• Regulators expect firms to conduct gap analyses of existing trust portfolios before the rules take effect. Lead trustees will need updated policies, revised client communications, and clear evidence of decision-making around exemptions.

Immediate next steps recommended:

1. Review all non-UK trusts holding UK land (pre- and post-2020).
2. Identify trusts that may qualify for the new de minimis or other exemptions.
3. Update internal TRS procedures and training.
4. Monitor the final commencement date (expected 21 days after the SI is made).

 SOURCES  

1. Official Draft Statutory Instrument (full text & contents): https://www.legislation.gov.uk/ukdsi/2026/9780348281743/contents
2. Full PDF of the Draft Regulations: https://www.legislation.gov.uk/ukdsi/2026/9780348281743/pdfs/ukdsi_9780348281743_en.pdf
3. Official Explanatory Memorandum (detailed policy explanation of TRS reforms): https://www.legislation.gov.uk/ukdsi/2026/9780348281743/pdfs/ukdsiem_9780348281743_en_001.pdf
4. Parliamentary SI page (laid 25 March 2026): https://statutoryinstruments.parliament.uk/instrument/8cBIMh8j
5. Regulation Tomorrow – Summary of Draft Regulations (including TRS changes): https://www.regulationtomorrow.com/2026/03/draft-money-laundering-and-terrorist-financing-amendment-regulations-2026/
6. CLC Guidance on New AML Legislation (including TRS changes): https://www.clc-uk.org/new-aml-legislation-expected-june-or-early-july-2026/
7. TLT Solicitors – Insight on 2026 AML Regulations & TRS impact: https://www.tlt.com/insights-and-events/insight/uk-government-strengthens-aml-and-crypto-controls-through-the-money-laundering-and-terrorist-financing-amendment-regulations-2026