New Trust Registration Rules: Is Your Offshore Property Structure Now Registrable?

The rules around the UK’s Trust Registration Service (TRS) have changed again, effective as of 30 June 2026. The new rules expand the scope of trusts involved in real estate holding structures (including Jersey Property Unit Trusts or Guernsey Property Unit Trusts) that will require to be registered.

Background

As we previously reported, the TRS imposed a number of reporting and transparency requirements on trusts, including the obligation to register on the TRS through HMRC. The scope of trusts that previously were in scope for registration (subject to certain limited exceptions) included any UK trusts and any non-UK trusts where the trust directly acquired an interest in UK land on or after 6 October 2020. 

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), which came into effect on 30 June 2026, have both further broadened the scope of those obligations and introduced some relaxations to the existing requirements.

What is new?

The key change for the commercial real estate sector is the expansion of the scope of non-UK property-owning trusts, such that a trust will now be registrable where it:

1. acquired UK property on or after 6 October 2020; or
2. acquired property before 6 October 2020 and continued to hold that property on or after 30 June 2026.

Until now, non-UK property trusts fell outside the TRS regime where the relevant UK property was acquired prior to 6 October 2020. The new additional limb (2) will bring further trusts under the TRS registration obligation that may previously have been considered outside of such obligation.

Action points

Those with trusts within their real estate holding structures (including Jersey Property Unit Trusts or Guernsey Property Unit Trusts) should reconsider whether any previously excluded trusts now fall within the scope of TRS. 

Penalties for non-compliance remain at HMRC's discretion and will be assessed on a case-by-case basis, but persistent failure to register or remedy inaccuracies following a warning may result in a fixed fine of £5,000. Failures to comply may also cause issues for sales or financings and therefore ensuring compliance in the context of such transactions is recommended. 

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