International Exchange of Information Manual

IEIM404510 - Mandatory Registration

The International Tax Compliance (Amendment) Regulations 2025 introduce a new mandatory registration requirement for Reporting Financial Institutions and Trustee-Documented Trusts.

All Reporting Financial Institutions and Trustee-Documented Trusts must register for HMRC’s AEOI service by the later of 31 December 2025 or 31 January following the calendar year in which the entity first falls within the definition of Reporting Financial Institution or Trustee-Documented Trust, for either or both of CRS and FATCA purposes. There must be a separate registration for each entity that is a Reporting Financial Institution or Trustee-Documented Trust.

For Reporting Financial Institutions that are already registered for AEOI, no further action is required.

When registering a Trustee-Documented Trust for AEOI, the Trustee-Documented Trust should be shown as the reporting Financial Institution, not the trustee. The reporting trustee should be named as a contact.

The registration is a single registration for AEOI covering both CRS and FATCA. Where an entity is within the scope of either CRS or FATCA but not both, there is no requirement to notify HMRC which of the regimes the entity falls within.

The registration is a one-off requirement. Once an entity has registered for the AEOI service it will remain registered for subsequent years unless it deregisters from the AEOI service.

If an entity registers for the AEOI service and has no Reportable Accounts, there is no obligation to submit a nil return, though the entity may choose to do so.

Entities that are newly brought within scope by CRS2.0, such as Electronic Money Institutions, will meet the definition of Financial Institution from 1 January 2026. The registration deadline for such entities is therefore 31 January 2027.

Financial Institutions that are taken out of scope by CRS2.0, for example charities meeting the criteria to be Qualified Non-Profit Entities may deregister from HMRC’s AEOI service from 1 January 2026. HMRC will accept that any such non-profit organisation that has not registered with HMRC’s AEOI service because it has never had Reportable Accounts is not required to register by 31 December 2025.