Automatic Exchange of Information

The UK’s rules for automatic exchange of information (AEOI) under the Common Reporting Standard (CRS) and the UK Foreign Account Tax Compliance Act (FATCA) were updated on 16 July 2025. All UK resident entities that would be classified as a “Reporting Financial Institution” (RFI) or as a “trustee-documented trust” are now required to register with HMRC.

What Is an RFI?

There are various categories of RFI which can capture entities including trusts, companies (including family investment companies), and partnerships. The “investment entity” category is often most relevant to our clients as this applies where most of the entity’s income comes from investing or trading in financial assets (shares, stocks etc) and it is managed by a financial
institution. In practice, an entity will therefore usually be an RFI if its principal asset is an investment portfolio which is managed by a professional discretionary investment manager.

What Is a Trustee-Documented Trust?

A trustee-documented trust has a trustee which is itself an RFI. The trustee has therefore submitted AEOI reports under its own requirements, meaning the trust itself has not previously been required to register. This will typically be the case where there is a professional corporate trustee

Registration Requirement

This is a one-off registration requirement that will extend to entities that have previously had no AEOI obligations. For example, a trust which falls within the definition of an RFI but has a UK settlor, UK trustees, and UK beneficiaries might not previously have been obliged to report

Automatic Exchange of Information:

Further changes to reporting requirements for UK trusts (and FICs) by 31 December 2025 to HMRC (because it had no reportable accounts in signatory jurisdictions) but will now be required to register.

The amendments to the regulations have also clarified self-certification and due diligence obligations. You should therefore ensure that you understand how these requirements would apply to you and that your due diligence records are up to date.

When Is the Deadline?

The deadline for existing entities to register with HMRC is 31 December 2025. A penalties regime has also been introduced, although we understand that penalties may not be automatically charged for late registration where reasonable efforts have been made to meet this deadline. Otherwise, the registration deadline is 31 January following the first calendar year in which the entity comes within scope.

What Should You Do Next?

01. Confirm the status of the entity for CRS and FATCA if you are not already aware of this. MTG would be happy to help with this analysis.

02. If the entity is an RFI or a trustee-documented trust, ask your accountant to assist you with registering with HMRC.

For further information, please speak with your usual MTG partner

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