comments on the proposed amendments to the UK’s Trust Registration Service (TRS) requirements, set out in the draft 2026 Regulation revising the 2017 Money Laundering, Terrorist Financing, and Transfer of Funds (AML) Regulations. The amendments were presented to Parliament on 25 March 2026 and are expected to be approved in June 2026.
Following a public consultation on “Improving the Effectiveness of the Money Laundering Regulations” held in September 2025, the UK government is bringing forward targeted amendments to close regulatory loopholes, address proportionality concerns, and account for evolving money-laundering and terrorist-financing risks — including weaknesses identified in pooled client accounts, trust registration, crypto-asset business regulation, and customer due diligence.
At a glance:
- TRS registration extended to older trusts holding UK land acquired before October 2020
- SDRT events will no longer, on their own, trigger mandatory TRS registration
- Disclosure requirements extended to non-UK “type C” trusts holding UK land
- Wider exemptions for low-value, low-risk trusts (under defined asset and income thresholds)
1. Older land-owning trusts brought into scope
The 2026 Regulations extend TRS registration requirements to all trusts, except those specifically excluded, that acquired an interest in UK land before 6 October 2020, provided they still hold that interest when the new Regulations take effect. As a result, older trusts previously exempt from TRS registration will now need to disclose their beneficial ownership information if they continue to own UK real estate (Regulations 24–26).
2. SDRT no longer an automatic trigger
Under Regulation 25(3), a trust incurring Stamp Duty Reserve Tax (SDRT) is no longer considered a “taxable trust” solely because of that event. SDRT events will no longer automatically require the trust to register on the TRS, reducing the cases where registration is mandatory.
3. Offshore trusts holding UK land
Regulation 27 extends disclosure requirements to “type C trusts” — non-UK express trusts not listed in Schedule 3A, where none of the trustees are UK resident, that acquire an interest in UK land in their capacity as trustees.
4. A wider net of exclusions for low-value trusts
Regulation 35(5) expands the list of excluded trusts under Schedule 3A, exempting additional low-risk or narrowly defined structures. The general exclusion for low-value trusts now applies to those that:
- do not hold any UK land;
- do not hold assets of appreciable worth exceeding £2,000 in total (including works of art, antiques, collectibles and jewellery);
- have not held property worth over £10,000 since creation; and
- do not have annual income exceeding £5,000.
This exclusion does not apply where the settlor has created other UK express trusts, one of which was previously excluded on these terms.
“The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 introduce targeted updates to strengthen the UK’s anti-money laundering (AML) and counter-terrorist financing (CTF) framework, ensuring continued compliance with Financial Action Task Force (FATF) standards. As part of these changes, HMRC intends to update the Trust Registration Service (TRS), focusing on high-risk trusts while simplifying compliance processes and improving consistency. Trustees, legal advisers, and compliance professionals must review existing arrangements to determine whether previously excluded trusts are now subject to the expanded registration requirements. While more trusts are included, the regulations also introduce exemptions for low-value, low-risk, and estate administration-related structures.”
— Tom Henderson, Capital Trustees
Why it matters
The direction of travel mirrors what is happening across most European registries: broader disclosure obligations for structures connected to real estate, paired with targeted relief for genuinely low-risk arrangements. Trustees of older UK land-holding trusts — including many long-standing family structures — should review their registration position well before the Regulations take effect, rather than waiting for the June 2026 approval.
Source: Capital Trustees AG,