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Action Reminder: Register with the TRS by September 2022

All unincorporated clubs with elected trustees need to register with the Trust Registration Service before September 1st 2022.

Clubs which have elected the ACC as trustees do not need to take action. Member’s institutions such as the ACC (The Association of Conservative Clubs) look after their members and will complete formalities for them. Equally, Clubs registered with the FCA do not need to take action.

All trusts must be registered. Once a trust is registered, any change to the trust must be submitted to HMRC within 90 days of the change occurring. Clubs must also update their details to the TRS once a year.

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Update January 10th 2022: –

What is the Trust Registration Service?

The body overlooking The Trust Register which is a detailing of all club’s trustee members and their assets.

Brought about June 2017, the HRMC registered body originated following the EU ruling on anti-money laundering. The Trust’s introduction is an attempt to improve transparency around the ownership of assets held by trustees.

Trustees must provide financial details including tax residence and assets, as well as potential beneficiaries. This information must be kept up to date by annual declaration.

Does My Club Need To Register with the Trust Registration Service?

All unincorporated clubs with elected trusteed will need to be aware of the expanded remit of the Trust Registration Service. All clubs will need to register with the TRS by 1st September 2022. Clubs registered with the FCA will not need to take action.

Clubs within associations, such as the ACC or The National Union of Liberal Clubs, should not need to register as associations will do this on your behalf. Check with your association or with your broker to find out whether you are correctly registered today.

Who does the Trust Registration Service Law affect?

The law affects all clubs with elected trusts including UK express trusts regardless of whether they incur liability to UK tax. Express trusts are required to register by the 10th March 2022, but is extended by 6 months for non-taxable trusts. Newly created trusts will be obliged to enroll after 3rd June 2022, 90 days from the event of their creation.

All newly appointed trustees will need to be registered by 1st September 2022. This can be done via this link:

The process is fairly lengthy and complex and involves submitting extensive information about the trustees and the beneficiaries of the trust.

Once a trust is registered, any changes such as a change of trustee, must be submitted to the HMRC within 90 days. Once a year, clubs will have to submit a return confirming that the Club have up to date details.

What if we have no members that want to take on the responsibilities?

The role of trustee management and ensuring your unincorporated club submits changes to HMRC each year is an important one. As a small unincorporated club you may struggle to find someone to fit that responsibility.

Once option is to transfer trusteeship to an association, such as the ACC or The National Union of Liberal Clubs. Associations will often pay for legal expenses involved with the transfer and will perform a lot of the complex admin for clubs around Acts such as the Trust Registration Service. Joining an association would also greatly strengthen a club’s financial and legal security and resources.

Similar to a broker, association are there in support of clubs. They do not impeach on the day-to-day running of clubs, but stand as a solid foundation, a safety net, that owners and operators can looks towards for guidance and support.

For advice on the Trust Registration Service or on how working with an insurance broker can support and secure your club’s finances, contact us. We are available via email or via a call to our local offices.

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