HMRC has introduced new registration rules under the UK’s Automatic Exchange of Information (AEOI) regime that will impact all UK Financial Institutions (FIs), including investment managers.
From 31 December 2025, firms must register with HMRC even if they do not maintain reportable accounts or submit annual AEOI returns. Failure to comply could result in significant penalties.
Overview
On 25 June 2025, HMRC introduced the International Tax Compliance (Amendment) Regulations 2025, amending the UK’s existing International Tax Compliance Regulations 2015. These changes align the UK’s regime with the Organisation for Economic Co-operation and Development’s (OECD) 2023 Common Reporting Standard (CRS) updates and introduce new compliance requirements for UK investment managers and other financial institutions.
The regulations came into force on 16 July 2025, with the first key deadline being 31 December 2025 for registration.
Key Changes
Mandatory HMRC registration
All reporting and specified non-reporting FIs must register with HMRC, regardless of whether they have reporting obligations.
Expanded compliance powers
HMRC may now request information from any FI, not just those with reportable accounts.
Updated penalty regime
The revised framework introduces penalties for:
- Failure to register with HMRC;
- Failures in due diligence or record-keeping;
- Not obtaining valid self-certifications;
- Late, incomplete, or inaccurate submissions; and
- Failure to provide information requested by HMRC.
Client notification
The previous requirement for certain FIs to notify clients of reporting has been removed.
Future expansion
From 2026, CRS will extend further to cover digital asset reporting under the OECD’s Crypto-Asset Reporting Framework (CARF).
What this means for UK investment managers
Even firms that have not previously filed AEOI returns are now required to register with HMRC. To remain compliant, investment managers should:
- Confirm their entity classification under FATCA/CRS.
- Complete HMRC registration ahead of the 31 December 2025 deadline.
- Review internal processes for due diligence, client self-certifications, and record-keeping.
- Prepare systems for expanded reporting from 2026.
How HaysMac can help
Our Financial Services Tax specialists can support you with:
- Entity classification under FATCA and CRS;
- HMRC registration and reporting processes, and;
- Reviewing compliance frameworks in line with the 2025 amendments.
If you would like to discuss how these changes may affect your business, please get in touch with our team.
