UK Automatic Exchange of Information changes: who needs to register by 31st December 2025?

You are probably already aware that the UK has recently adopted changes into legislation that require certain entities to register for the Automatic Exchange of Information (AEOI) regime that is operated by HMRC. This is often referred to as the Common Reporting Standard (CRS). Although this is not a tax matter HMRC, is acting as the part of Government responsible for administrating the regime.

The new rules are complex and there is currently uncertainty who must register. However, our current understanding is that all non-natural persons that use advisors and/or managers to invest funds should register. This will include companies, partnerships and trusts.  HMRC have produced several examples of investment entities that fall under the legislation.

The deadline for registration is 31st December 2025.

Who needs to register?

According to HMRC guidance, you should register for the AEOI if you:

• Are a Financial Institution (whether or not you have information to report)
• Are a Trustee-Documented Trust (whether or not you have information to report)
• Need to file a return on behalf of a financial institution

We understand that HMRC requires anyone liable to register to do this themselves as it must be done via an entity’s Government Gateway Portal. If you do not have one, it can be set up as part of the registration process.

We recommend you review the definitions and speak to your FCA investment and/or legal advisors around the changes and how they can help you.  Unfortunately, we are unable to do this for you.

Penalties

HMRC may charge a penalty of £1,000 for failing to register on time, with further penalties of £300 per day if the failure continues after the initial penalty notice has been issued.

How to register

Registration can be made using the following:  https://www.gov.uk/guidance/register-for-automatic-exchange-of-information