UK: Updated International Exchange of Information manual

HM Revenue and Customs (HMRC) on September 26, 2025, updated its International Exchange of Information Manual (IEIM) to introduce a new section—IEIM404510 (mandatory registration)—under section IEIM404500 (reporting format).

The key updates are as follows:

• Reporting financial institutions and trustee-documented trusts (TDTs) are now required to register with HMRC’s automatic exchange of information (AEOI) service by December 31, 2025, or January 31 following the calendar year in which they first qualify as a reporting financial institution or TDT for FATCA and common reporting standard (CRS) purposes. Each reporting financial institution and TDT must complete separate registrations.
• Reporting financial institutions that are already registered do not need to take any further action.
• TDTs must be registered by their own name, while the trustee should be listed as a contact person.
• A single registration applies to both FATCA and CRS. Entities falling within the scope of only one regime are not required to notify HMRC of which regime applies.
• Registration is a one-time requirement. Once registered, the entity remains registered for future years unless it chooses to deregister.
• Entities with no reportable accounts are not obligated to file NIL returns, although they may choose to do so voluntarily.

Read an October 2025 report prepared by the KPMG member firm in the UK