If you are a trustee or manage a company with investment income, please take note of an upcoming deadline that you may be required to comply with. The UK Government has introduced changes to the Automatic Exchange of Information (AEOI) rules, which impacts certain trusts, companies, and partnerships.

If your entity qualifies as a Financial Institution (FI) under the Common Reporting Standard (CRS) or Foreign Account Tax Compliance Act (FATCA), you must register with HMRC by 31 December 2025 - even if you have no reporting obligations. Where there are reporting obligations, you must also file a return by 31 May following the end of the relevant calendar year, but the entity must still be registered by 31 December 2025 if it has not already been registered. 

Who is affected?

• Trusts, companies, and partnerships meeting the FI definition.
• Trustee-Documented Trusts, where a corporate trustee handles reporting, must also now register.

The FI definition is broad. For trusts, the key test is:

• 50% or more of the income is derived from investments, and
• Use of a discretionary fund manager or have a ‘corporate trustee’.

The term Financial Institution  doesn’t just mean banks - it can include family trusts and investment-focused entities such as companies or partnerships. 

What’s changed?

Previously, only FIs making AEOI returns needed to register. Now, all reporting FIs and Trustee-Documented Trusts must register, even if they have nothing to report.

Key actions for trustees:

1. Confirm if the trust meets the FI definition.
2. Register with HMRC for AEOI by 31 December 2025.
3. Obtain self-certification from all parties (settlor, trustees and beneficiaries).
4. Notify parties that their data may be shared internationally.

Penalties for non-compliance:

• £1,000 for failing to notify.
• Daily penalties up to £300 for continued failure.

Registration is via HMRC’s AEOI portal: Register for Automatic Exchange of Information - GOV.UK.