UK Automatic Exchange of Information (AEOI): Do you need to register by 31 December 2025?

The UK has recently introduced legislative changes that expand the scope of entities required to register under the Automatic Exchange of Information (AEOI) regime, administered by HMRC. This regime is more commonly known as the Common Reporting Standard (CRS).

While AEOI is not a tax regime, HMRC is responsible for its administration and enforcement. The updated rules are complex and, in some areas, remain unclear. However, based on current guidance, many more entities are now likely to fall within scope.

What is Automatic Exchange of Information?

AEOI is an international information-sharing framework designed to prevent tax evasion by requiring financial institutions to report certain financial account information to HMRC, which is then shared with other tax authorities where appropriate.

Who is likely to be affected?

Under the revised rules, most non-natural persons that invest funds through advisers or managers are expected to be required to register. This may include:

• Companies
• Partnerships
• Trusts

HMRC has published examples of investment entities that fall within the scope of the legislation, indicating that the regime applies more widely than before.

Who must register?

According to HMRC guidance, you must register for AEOI if you:

• Are a Financial Institution, even if you have no reportable information
• Are a Trustee-Documented Trust, even if you have no reportable information
• Are required to submit a return on behalf of a Financial Institution

What has changed?

The legislation has expanded the definitions of both entities and individuals required to register. The changes now bring the following within scope:

• Most FCA-regulated investment entities
• Certain digital asset holding companies
• UK representatives, in addition to financial institutions themselves

Under the updated rules, a Financial Institution includes:

• Custodial institutions
• Depository institutions
• Investment entities
• Specified insurance companies

As a result, your entity may now be classified as an investment entity if it invests in, administers, or manages financial assets or money on behalf of others.

Registration responsibilities

HMRC requires all entities that are liable to register to do so themselves. Registration must be completed through the entity’s Government Gateway account. If an account does not already exist, one can be created during the registration process.

Given the complexity of the rules, entities should carefully review the definitions and seek advice from their FCA-regulated investment advisers and/or legal advisers to determine whether they fall within scope.

Registration deadline

The deadline to register for AEOI is: 31 December 2025

Penalties for non-compliance

HMRC may impose the following penalties for failure to register on time:

• An initial penalty of £1,000
• Additional penalties of £300 per day if the failure continues after a penalty notice has been issued

How to register

Registration can be completed online via HMRC’s website: https://www.gov.uk/guidance/register-for-automatic-exchange-of-information

If you require help or advice, your can also reach out to me at acshah@geraldedelman.com.