Important Changes to the UK Trust Registration Service

The UK Government has now implemented changes to the Trust Registration Service (TRS) which significantly expand the registration requirements for certain non-UK trusts holding UK real estate. The changes form part of the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), which were made on 9 June 2026 and, with limited exceptions, came into force on 30 June 2026.

These changes will be of particular relevance to structures commonly used by institutional real estate investors, including Jersey Property Unit Trusts (JPUTs) and Guernsey Property Unit Trusts (GPUTs).

What has changed?

Prior to these amendments, a non-UK trust generally became subject to TRS registration where it directly acquired an interest in UK land on or after 6 October 2020.

The new legislation expands the scope of the regime by bringing within TRS registration requirements certain non-UK trusts that:

• acquired an interest in UK land before 6 October 2020; and
• continued to hold that interest on the date the new provisions came into force.

The relevant amendment inserts a new provision into the Money Laundering Regulations which applies to trusts that: “acquired an interest in land in the United Kingdom before 6th October 2020 and continued to hold that interest up to and including the date on which this sub-paragraph comes into force”.

In practical terms, this closes a gap in the previous regime and extends registration obligations to a significant number of long-established offshore real estate holding structures, including many JPUTs and GPUTs.

What does this mean for JPUTs and GPUTs?

For many years, a number of offshore property trusts fell outside the TRS regime because the relevant UK property had been acquired before the introduction of the existing registration trigger.

Following the introduction of the 2026 amendments, trustees should no longer assume that a historic acquisition date removes the need for registration.

As a result, JPUTs, GPUTs and other non-UK express trusts that continue to hold UK real estate should review their position carefully to determine whether they have now become registrable under the expanded rules. Nearly all JPUTs and GPUTs should be assumed to be registerable now if it still continues to hold UK Property directly.

Why were the changes introduced?

The amendments form part of the Government’s wider programme of anti-money laundering and beneficial ownership transparency reforms.

The original proposals were published by HM Treasury in draft form during 2025 as part of a broader consultation on improving the effectiveness of the UK’s Money Laundering Regulations and Trust Registration Service framework.

The final 2026 Regulations have now implemented a number of those proposed changes, including the expansion of trust registration requirements.

Action points for trustees

Trustees of non-UK property holding trusts should consider:

• whether the trust directly owns UK land or property;
• when the relevant UK property interest was acquired;
• whether the property continued to be held on 30 June 2026;
• whether any exemption may apply; and
• whether a TRS registration or update is now required.

This review should be undertaken promptly, particularly for longstanding JPUT and GPUT structures which may previously have concluded that registration was not required.

What is the UK Trust Registration Service?

The TRS was implemented as a way of HMRC understanding more details around which trusts were in existence. Even nominee relationships can be caught and required to be registered, so careful consideration should be given to the registration requirements to ensure compliance.

The registration is made with HMRC and the details are not publicly available. The TRS requires the trustee to provide details of:

• The Trustee(s) (in the case of two or more trustees a lead trustee is required to be selected)
• The Settlor(s)
• The Beneficiaries
• Any Protectors
• Details of any company based outside the EU, Norway, Iceland or Liechtenstein where the trust has a controlling interest in that company

There is a requirement for this information to be kept up to date as and when there are changes, and in certain circumstances an annual filing may be required.

Further information on TRS can be found on the HMRC website.

How we can help

At Mourant Governance Services, we can assist trustees, managers and investors in assessing whether a trust falls within the expanded TRS regime, determining the information required for registration and managing the ongoing compliance obligations arising from registration.

If you would like to discuss the application of the new rules to your structure, please contact a member of our Real Estate or Governance Services team.