UK: HMRC publishes guidance on mandatory registration under CRS, FATCA

HMRC requires reporting financial institutions and trustee-documented trusts to register under CRS and FATCA by 31 December 2025, with CRS 2.0 updates affecting certain entities from 2026.

UK’S HMRC has released guidance in its International Exchange of Information Manual regarding the compulsory registration of reporting financial institutions and trustee-documented trusts under the OECD’s Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA) on 26 September 2025.

Under the International Tax Compliance (Amendment) Regulations 2025, all RFIs and Trustee-Documented Trusts are required to register with HMRC’s AEOI service. Entities must complete registration by the later of 31 December 2025 or 31 January following the calendar year in which they first meet the definition of an RFI or Trustee-Documented Trust for CRS or FATCA purposes. Each entity that qualifies must submit a separate registration.

Reporting Financial Institutions that are already registered with AEOI are not required to take further action. In the case of Trustee-Documented Trusts, the trust itself should be shown as the reporting Financial Institution, while the trustee should be listed as the contact person. The registration is a single process covering both CRS and FATCA, and entities do not need to specify which regime applies to them.

The registration is a one-off requirement. Once an entity has registered for the AEOI service, it remains registered for subsequent years unless it deregisters. Entities with no Reportable Accounts are not obliged to submit a nil return, although they may do so voluntarily.

With the introduction of CRS 2.0, certain entities such as Electronic Money Institutions are newly considered Financial Institutions from 1 January 2026. The registration deadline for these entities is 31 January 2027. Entities removed from scope under CRS 2.0, including charities that qualify as Non-Profit Entities, may deregister from HMRC’s AEOI service from 1 January 2026. HMRC will also accept that non-profit organisations that have never held Reportable Accounts are not required to register by 31 December 2025.