FATCA/CRS: UK New Mandatory Registration Regs

On September 26, 2025, the United Kingdom’s HMRC updated its International Exchange of Information Manual to include a new section on Mandatory Registration. This new requirement is for Reporting Financial Institutions (FIs) and Trustee-Documented Trusts.

Who & When?

All Reporting FIs and Trustee-Documented Trusts must register by the later of December 31, 2025 or January 31 following the calendar year in which the entity first falls within the definition of Reporting FI or Trustee-Documented Trust for FATCA or CRS or both FATCA and CRS. This point is a useful reminder that there is not a 100% overlap in classifying all entities under FATCA and CRS. It is also important to classify an entity under the relevant jurisdiction’s local implementation of FATCA and CRS and to review the particular jurisdiction’s FATCA Intergovernmental Agreement (IGA) with the U.S.

The registration is not an annual requirement. Once an entity has registered in HMRC’s AEOI portal, there is no further action to take unless an entity must deregister. Reporting FIs which have previously registered in HMRC’s AEOI portal do not have to take further action related to this new regulation.

CRS2.0

Entities which will be classified as FIs pursuant to CRS2.0 beginning January 1, 2026 must register in HMRC’s AEOI portal by January 31, 2027.

One impact of CRS2.0 is that certain entities which were previously classified under CRS as FIs will no longer be in scope for CRS. If such an entity had not previously registered in HMRC’s AEOI portal because it had no reportable accounts, it will not be required to register under the new regulation. This is because the practical impact would be the entity registering by December 31, 2025 and then not being subject to CRS on January 1, 2026.

HMRC Registration Tips

The new regulation provides useful information regarding the online registration process: https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim404510

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.