Professional Adviser ran a piece this week arguing that the Trust Registration Service is worth more to a financial adviser than its reputation as a compliance chore suggests: that the register is a way into estate and tax planning conversations, and that demand for those conversations is rising ahead of the inheritance tax changes coming to pensions. The argument is a good one. It also has a hole in it, and the hole is the interesting part.
In a great many cases the adviser is not the professional holding the register entry. The accountant is. The firm that identified the trust, obtained the unique taxpayer reference, registered it inside its agent services account, files the annual declaration and reports every change within 90 days is the firm that knows the trust exists at all. Which means the list that the advice profession is being told to go and find is, for most of these clients, already sitting in an accountancy practice — usually filed under compliance, reviewed once a year, and read by nobody as a client list.
What is actually on the register
The scale is not marginal. HMRC's Statistics on trusts in the UK, published on 18 December 2025, records 835,000 trusts and estates registered up to 31 March 2025 that remained open as at 29 August 2025. Separately, 157,000 trusts and estates submitted a Self Assessment return for the tax year ending 2024, up 3% on the year before, paying £1.62 billion in income tax and capital gains tax between them — £1.01 billion of income tax and £605 million of capital gains tax.
The obligations behind those numbers are firmly administrative, and they are the accountant's. HMRC's guidance for trustees requires all UK resident express trusts to register unless they are excluded as a Schedule 3A trust, with a non-taxable trust created after 6 October 2020 registered within 90 days of creation or of becoming liable for tax. Changes must be reported within 90 days of them occurring. A taxable trust must be declared up to date every year by 31 January. And the guidance is blunt about what happens if the whole thing is missed: a £5,000 penalty.
None of that is advice. All of it is knowledge. A registered trust tells you there is a settlor who decided, at some point, that assets should not simply pass under a will; that there are named beneficiaries; that somebody took a view about control, or tax, or a second marriage, or a child who could not be handed a lump sum. That is a compressed fact pattern about a family's intentions, and your firm typed it in.
Why 6 April 2027 changes the weight of that list
The reason this stops being an interesting observation and becomes a dated one is the pension change. The HMRC and HM Treasury policy paper Inheritance Tax: unused pension funds and death benefits, published on 26 November 2025, confirms that from 6 April 2027 unused pension funds and pension death benefits fall into the estate for inheritance tax. Personal representatives will be liable for reporting and paying the tax due on those amounts, with the option to direct the scheme administrator to pay it or to reimburse them.
Several things are carved out, and they matter as much as the charge itself. The existing exemptions for death benefits passing to a surviving spouse or civil partner, and to registered charities, are maintained. Death in service benefits payable from a registered pension scheme are excluded, as are dependants' scheme pensions from a defined benefit or collective money purchase arrangement.
Put real numbers on it. Take a client who dies in June 2027 leaving a house and investments worth £600,000 and an untouched defined contribution pension of £450,000, all passing to adult children, with the standard £325,000 nil-rate band available and no residence nil-rate band claimed. Under today's treatment the estate is £600,000, the taxable slice is £275,000, and at the standard 40% rate the bill is £110,000 — the pension sitting outside it. From 6 April 2027 the estate is £1,050,000, the taxable slice is £725,000, and the bill is £290,000. The difference is £180,000, which is simply 40% of the pension pot.
A trust on the register and an untouched pension in the same client file are, from April 2027, a single planning question. They are currently being handled by two people who have never spoken.
That £180,000 is the part worth sitting with. A meaningful number of business owners were told, entirely sensibly under the rules as they stood, to leave the pension alone and spend other money first, precisely because the pension sat outside the estate. For anyone who followed that advice and has not revisited it, the strategy inverts. And the professional most likely to know both that a trust exists and that the pension has been deliberately left untouched — because they see the drawings, the dividend pattern and the personal tax return — is the accountant, not the pension provider.
What joined-up actually means here
This is where the two professions have complementary halves of one picture and rarely assemble it. The accountant knows the client's income pattern, what the business will be worth on exit, which assets are already in trust, whether there is a second family, and what the client has been extracting and why. The financial planner knows the scheme rules, the expression of wish, whether the pension is a defined contribution pot that will now be caught or a defined benefit arrangement that largely will not, and what the drawdown and gifting options do to the position.
Neither half is much use alone. An expression of wish form completed a decade ago, pointing at a spouse who has since died, is a small piece of paper that can move six figures — and it is nobody's job to look at it unless somebody joins the file up. A trust that was set up to hold a shareholding, sitting alongside a shareholders' agreement that says something slightly different, has the same quality: entirely visible, entirely unread.
This is the same pattern we described in the six signals already sitting in your client file. The trust register is the seventh, and it is the most legible of them, because unlike a hunch about surplus cash it is a definite list with names and dates on it. The boundary question — where the accountant's role ends and regulated advice begins — is set out in who does what, and it does not move because the subject is estates rather than investments.
Three things to do this week
First, pull the list. Every firm that registers trusts can produce the trusts it has registered or declares for. Most partners have never seen it as a single sheet of paper, and reading it in one sitting is a genuinely different experience from meeting each entry once a year in isolation.
Second, filter it three ways: settlors and life tenants in their seventies or older; clients holding a defined contribution pension they have deliberately left untouched for estate reasons; and trusts holding shares in a trading company. The first group has a live estate question, the second group's strategy inverts on 6 April 2027, and the third needs the trust, the shareholders' agreement and the succession plan to agree with one another. That filter usually produces a short list rather than a mailing list, which is the point.
Third, remember what the register does not show you. Trusts holding life policies that only pay out on death, illness or disability are excluded from registration, as are trusts holding assets of a UK registered pension scheme, unless they become liable to UK tax. So an empty-looking register says nothing whatsoever about whether a client has protection in place. That is a separate exercise, run off the accounts and the personal guarantees rather than off the register, and it is the one covered in the joined-up exit when a sale is in motion.
What is not yet settled
Two honest caveats. The pension measure applies to deaths on or after 6 April 2027, so no estate has yet been administered under it and the profession has no practical experience of how the personal representative's reporting duty interacts with obtaining a valuation from a scheme administrator inside the inheritance tax account deadline. That will be learned in 2027 and 2028, not before. And the policy paper behind all of this was published on 26 November 2025; inheritance tax is revisited at most fiscal events, so the detail as it stands is the detail as legislated, not a permanent settlement.
What is settled is the direction, the date, and the arithmetic. Which is enough to justify reading a list your firm already maintains with a different question in mind.
The wider point about who opens these conversations
The lang cat's State of Advice Report 2025 found that just 9% of UK adults had paid for financial advice in the preceding two years, while 91% of those who did take advice found it valuable. It also put the average age of an IFA client at 59 and the average new client portfolio at £411,000. Read together, those figures describe a profession serving a narrow slice of the population very well and reaching almost nobody outside it — not because people refuse help, but because nobody they trust ever raises it. We set that argument out in full on the advice gap.
A trust register is a small, specific antidote to that. It is a list of people who have already demonstrated they think about what happens to their assets after them, held by the professional they trust most, in the year before the rules on the biggest asset in the picture change. Whether that list gets read or filed is a decision each firm makes for itself.
Common questions
Does registering a client's trust make our firm a financial adviser?
No. Registering a trust on HMRC's Trust Registration Service, reporting changes within 90 days and making the annual declaration for a taxable trust are tax administration. None of it is a regulated activity, and none of it requires FCA authorisation. The line your firm should not cross is the next one: advising the client on whether a particular product, pension withdrawal pattern or investment is suitable for them. Noticing that a trust and an untouched pension sit in the same client file, and saying so, is observation. Recommending what to do about it is regulated advice, and belongs with an authorised firm. We set out the division in full in our article on who does what.
Which trusts have to be registered, and by when?
HMRC's guidance requires all UK resident express trusts to register unless they fall within the Schedule 3A exclusions, along with any trust that becomes liable to UK tax. A non-taxable trust created after 6 October 2020 must be registered within 90 days of being created or of becoming liable for tax. Once a trust is on the register, changes to it must be reported within 90 days, and a taxable trust must be declared up to date every year by 31 January. HMRC's guidance states that failure to register a trust can attract a £5,000 penalty. Trusts holding assets of a UK registered pension scheme, and trusts holding life policies that only pay out on death, illness or disability, are excluded unless they become liable to tax.
What actually changes for pensions on 6 April 2027?
From 6 April 2027, unused pension funds and pension death benefits come into the estate for inheritance tax purposes. The HMRC and HM Treasury policy paper published on 26 November 2025 confirms that personal representatives will be liable for reporting and paying the tax due on those amounts, with an option to direct the scheme administrator to pay it or reimburse them. The existing exemptions for death benefits passing to a surviving spouse or civil partner and to registered charities are maintained. Death in service benefits payable from a registered pension scheme, and dependants' scheme pensions from a defined benefit or collective money purchase arrangement, are excluded from the change.
Our client's life policy is written in trust — does that need registering?
Usually not. HMRC's guidance excludes a trust holding life insurance policies that only pay out on death, illness or disability, unless that trust becomes liable to UK tax. So a straightforward pure protection policy written in trust sits outside the register. That exclusion is worth understanding rather than filing away, because it means the absence of a trust on your register tells you nothing about whether protection exists. The register shows you the trusts that had to be reported; it does not show you the protection gaps, which is a separate exercise using the accounts, the personal guarantees and the shareholding.
How do we decide which trust clients are worth a conversation?
Three filters get you most of the way. First, settlors and life tenants in their seventies or older, where the estate is the live question rather than a distant one. Second, any client who holds a defined contribution pension they have deliberately left untouched for estate reasons, because that position changes on 6 April 2027. Third, trusts holding shares in a trading company, where the trust, the shareholders' agreement and the succession plan need to agree with one another. Run those three against the trusts your firm registered and you will typically surface a short list, not a mailing list.