Use this 10-step guide to help you report your Employee Ownership Trust (EOT) or Employee Benefit Trust (EBT) to HMRC via the Trust Registration Service (TRS).  The deadline for existing trusts  is 1 September 2022 and for all new trusts the deadline is within 90 days of creation.


Anti-money laundering legislation required all tax-paying trusts to register with HMRC’s Trust Registration Service (TRS). Trustees were obliged to register their trust if it had any liability to UK income tax, Capital Gains Tax, Inheritance Tax, Stamp Duty Land Tax or Land and Buildings Transaction Tax (in Scotland).

As most EOTs and EBTs are funded by contributions from the company, then they are unlikely to have any tax liabilities. As such, they did not have to register. This changes as of 1st September 2022.

The requirement to register with the TRS will be extended to include trusts where all the Trustees are UK resident, or if one of the Trustees are UK resident and the settlor (former owner/s) were UK resident at the time the trust was established. This new requirement will include almost all Employee EOTs and EBTs.

Registration is simple and straightforward. This can be outsourced to a non-Trustee; for example, your Financial Director or external Accountant, but the responsibility for the information held with the TRS remains with the Trustees. Your Trust will have to appoint a Lead Trustee who will be the point of contact for HMRC.

Follow this 10-step guide to register your EOT or EBT.

Step 1 – Assemble the information required

You will need information on the EOT/EBT, the Trustees and the Settlors (the former owners who transferred the assets to the trust).

The EOT/EBT information can be found in the Trust deed. You will be asked for:

  • The name of the trust
  • The date the trust was created
  • The EOT/EBT will be an express trust
  • Is it a UK trust (answer to this will be yes)
  • Has it purchased any UK land or property (likely answer is no)

The Lead Trustee will need to provide:

  • name
  • date of birth
  • National Insurance number and address (if they are a UK citizen)
  • passport details and address (if they are not a UK citizen)
  • telephone number
  • country of residence
  • country of nationality

Information on the other Trustees required:

  • name
  • date of birth
  • country of residence
  • country of nationality
  • mental capacity at the time of registration — HMRC will assume the individual has mental capacity, unless you say otherwise

Settlors are the individuals who transferred the assets into the trust. In employee-owned companies, this will be the former owners who sold a shareholding to set up the trust. You will need the following for each settlor:

  • name
  • date of birth
  • country of residence
  • country of nationality
  • mental capacity at the time of registration — HMRC will assume the individual has mental capacity, unless you say otherwise

You will be asked for information on the trust beneficiaries:

  • Your beneficiaries will be an employment related category
  • Description; for example, employees of CDS Ltd with more than six months’ service
  • Number – you will be asked to tick a parameter e.g., 1-100

Step 2 – Obtain Government Gateway Log –In

Each trust will require its own Government Gateway Log-in. Go to and hit the Register Now button. This will take you to a page asking for your Government Gateway Log-in. Choose the option Create Sign In details. You will be asked to enter your email address. HMRC will email you a code to confirm your email address. Once you have entered the code, you will be taken to the page to commence registration. Enter your name and create a password. You will then see your trust’s Government Gateway Log-in. Take a note of this as you will need it when you make any amendments to the information (e.g. a change in the trustees).

Step 3 – Additional security

After choosing the Organisation category, you will be asked to set up additional security. You will be given three options to receive an access code. You will be asked if the trust is already registered. If you are registering for the first time the answer will be no. You will then be asked for a Unique Taxpayer Reference. It is unlikely your Trust will have this so the response will be no.

Step 4 – About the type of trust

You will be asked for information about the trust. Your EOT/EBT will be an express trust. You will be asked if the trust has a tax liability for the current year or the past four years. The answer to that will likely be no.

Step 5 – Trust registration – Trust details

The first question is to provide the name of the Trust. You will find this in your Trust Deed. You will then be asked to say when the trust was created. This will be in your Trust Deed. It is likely that it will be the day that the transaction completed for the transfer to employee ownership, but in a few cases the trust may have been set up in advance of the transaction.

You will then be asked if the trust owns property and if it operates outside the EEA. The answers to both questions will likely be no. The next question is whether all trustees are based in the UK.

Step 6 – Trust Registration –Settlor

The Settlors are the selling shareholders who created the trust. You will be asked to input the information you gathered as per above.

Step 7- Trust Registration – Trustees

You will be asked to input the Trustee information.

Step 8 – Trust Registration – Beneficiaries

The EOT will have Company or Employment Related beneficiaries and will be Employees and/or their families. You will be asked for the name of the business and if it is a UK business. You will then be asked to describe the beneficiaries. The Trust Deed will define the qualifying period for beneficiaries; it can be anything up to 12 months’ service. A description might be “an employee of CDS Ltd with more than 12 months’ service”.

You will be asked for the number of employees within wide parameters e.g. 1 –100, 101-200, 201-500 etc.

Step 9 – Trust Registration – Additional sections

You will be asked for further information regarding the trust. The responses to these questions will likely be no for EOTs/EBTs.

Step 10 – Declaration

You will be asked to declare that all information provided is accurate, and that you are aware that you have knowingly provided false information you may be subject to penalties.

Once this is confirmed you will be given the Unique Reference Number for the trust and you will have the option to save and/or print the registration.


Should your trust require to be amended, for example, when a new Trustee is appointed, then you have 90 days to make that amendment. You will require the Government Gateway Code and your password.

If you run into any difficulties or have any queries then your accountant may be able to advise, otherwise HMRC have a helpline on 0300 123 1072.