INTM917410 - DRAFT: The International Controlled Transaction Reporting Regulations: Regulations Part 1
This guidance is in draft. It covers the International Controlled Transaction Reporting Regulations 2026 (‘the Regulations’), which were laid before the House of Commons on 4 November 2026. HMRC aims to publish the ICTS notice on 26 November 2026 (when the Regulations come into force), and detailed guidance on the ICTS notice in this manual by 31 December 2026, prior to the reporting requirement coming into effect from 1 January 2027.
Introduction
Part 1 acts as an introduction to the International Controlled Transaction Reporting Regulations 2026 (the ‘Regulations’), and covers regulations 1, 2 and 3. This part details how the Regulations should be cited, the date the provisions come into force, and the periods to which they apply (regulation 1). Part 1 also defines how key terms are interpreted for the purposes of the Regulations (regulation 2) and sets the scope of a notice that can be published by HMRC’s Commissioners under these Regulations (regulation 3).
Regulation 1: Citation, commencement and application
The Regulations come into force on 26 November 2026. The requirement to report under the Regulations only applies to accounting periods beginning on or after 1 January 2027 (regulation 1(2)(a)).
The requirement to report under the Regulations applies to underwriting years beginning on or after 1 January 2027 where the profits or losses arising to a Lloyd’s member in any underwriting year directly from its membership of one or more syndicates are required to be declared on or after 1 January 2030 (regulation 1(2)(b)). In practice this means the reporting requirement applies from the 2027 Year of Account comprising underwriting years 2027, 2028 and 2029.
Regulation 2: Interpretation
Regulation 2 defines key terms, both those created for the purposes of the ICTS and those taken from existing legislation. Where terms are taken from existing legislation, the references are provided.
For ease, a Glossary of Terms will be provided at INTM917310 which brings together guidance on the interpretation of key terms from the primary (FA26/S48), secondary (the Regulations) and tertiary legislation (the Notice).
Regulation 3: Notice
As explained in the overview of the legislative framework (INTM917330) the primary legislation (FA26/S48(2)) gives the Regulations the power to defer detail on the reporting requirement to an HMRC notice. Regulation 3 outlines the scope of that power. A notice issued by the Commissioners for HMRC may:
- Apply to all cases (such as all reporting entities, or all SICTs)
- Apply to some cases (some reporting entities, or some SICTs), subject to specific exceptions
- Apply to specific cases, or cases of a specific description
- Make different provisions for different purposes.