HMRC’s Trust Register

2 Aug 2022 Denise Copeland    Last updated: 2 Aug 2022

Some unincorporated not for profit organisations which have assets held in trust may be required to register their Trusts with HMRC's Trust Registration Service.  The deadline is 1 September 2022.

The Trust Registration Service (TRS)

The Trust Registration Service (TRS) is a register of the beneficial ownership of trusts which was introduced under the Money Laundering, Terrorist Financing and Transfer of Funds regulations.  It was set up initially in 2017 and required trustees to register if their trusts were liable to pay any of the following taxes: income tax, capital gains tax, inheritance tax or stamp duty tax.  

The scope of the Trust Register was extended in October 2020 to UK trusts (and some non-UK trusts) regardless if the trust was liable to pay tax.   There are some exclusions with the requirement to register which includes charities but does not include CASCs. 

Unincorporated Associations and Community Amateur Sports Clubs (CASCs)

In it’s guidance on which trusts must register, HMRC explains:

"Community clubs and associations are often structured as unincorporated associations, meaning that the association itself has no legal capacity. Unincorporated associations can be structured in a number of different ways and often the property of the association is held on trust by some or all of the members for the benefit of the wider membership. This may be evidenced by the existence of a document known as a trust deed or declaration of trust.

An unincorporated association structured as an express trust is not required to register if it is registered as a charity in the UK. This exclusion does not apply to associations that are not registered as a charity but are instead registered with HMRC as community amateur sports clubs (CASCs).”

How to register

Guidance on what is needed to register and the link to the online registration form can be found here Register a trust as a trustee - GOV.UK (  Please note that your organisation will need a Government Gateway Account to be able to register the trust on the TRS.'s picture
by Denise Copeland

Governance and Charity Advice Manager

[email protected]

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