The new money laundering regulations require trustees of pension schemes that are liable for certain taxes (called “relevant UK taxes”) to register with the HMRC’s Trusts Registration Service (TRS). Those who fall within this category face potentially burdensome reporting requirements.

Most UK occupational pension schemes will not need to register on TRS. However, for schemes that do need to register and are either registered for self-assessment or do not require self-assessment registration, the deadline for registration on TRS will be 31 January after the end of each tax year. However, for the first year of TRS only, HMRC has stated that it will not impose a penalty for the failure to register existing trusts on TRS by 31 January 2018, so long as they register by 5 March 2018.

Trustees of pension schemes which have incurred a liability to relevant UK taxes for the first time in the tax year 2016-17 must still have registered on TRS by 5 January 2018.