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The deadline to report Automatic Exchange of Information(AEOI) data for the year ended 31 December 2025 is 31 May 2026. If your trust, charity, or investment-managing business has overseas beneficiaries, you may need to act now.
The Automatic Exchange of Information, more commonly known as AEOI, is a framework designed to tackle international tax evasion. The UK is a signatory to this scheme, which operates under the Common Reporting Standard(CRS). In practice, it means that certain UK entities with overseas beneficiaries must report information about those beneficiaries and the payments made to them, to HMRC.
This is not the same as the AEOI Registration process, which was completed in December 2025. This is a separate, annual reporting obligation, and the deadline is fast approaching.
Key deadlines at a glance:
- 31 May 2026 - Report for the year ended 31 December 2025
- 31 January 2027 - Report for new or newly qualifying entities (formed or changed since 1 January 2026) for the year ended 31 December 2026
Who is affected?
AEOI reporting applies to UK entities that make payments to overseas beneficiaries. The main groups affected are:
- Trusts with discretionary managed investments and overseas beneficiaries
- Charities with overseas beneficiaries (note: charities are exempt from FATCA but are subject to CRS requirements)
- Companies or partnerships that manage investments for customers and have overseas connections
In practice, the number of entities required to report each year is relatively small. But the consequences of missing the deadline, even inadvertently, make it essential to check.
When does a trust nmeed to report?
Not every trust falls within the AEOI reporting requirement. A trust will normally need to file a return only if both of the following conditions are met:
- More than 50% of the trust's gross income is primarily from financial assets, not rental income
- The trust's investments are managed by a Financial Institution on a discretionary basis, meaning a broker or similar professional has discretionary power overinvestment decisions, rather than simply providing advice.
An important distinction: if a broker makes recommendations but the trustees retain final decision-making authority over the buying andselling of assets, that does not constitute discretionary management. The trust would not meet the second condition and would not be required to report.
What about charities?
Charities are treated slightly differently. They are exempt from FATCA (the US Foreign Account Tax Compliance Act) reporting requirements, but they are not automatically exempt from CRS (Common Reporting Standard)obligations.
If your charity has overseas beneficiaries, it is worth taking specialist advice to confirm whether a report is required. HMRC guidance provides a useful starting framework, but the nuances can be complex.
New or newly qualifying entities: The January 2027 deadline
A separate deadline applies to entities that are new to AEO requirements. If your trust, charity, partnership or company was formed after 1January 2026, or has experienced a change in assets, management, or trustees since that date which now brings it within the registration conditions, the first reporting deadline for the year ended 31 December 2026 will be 31 January 2027.
This is distinct from the AEOI Registration process completed in December 2025 and relates specifically to the annual reporting obligation going forward.
What should you do now?
Given the 31 May 2026 deadline, there is limited time to establish whether a report is required for the 2025 tax year. We recommend taking the following steps:
- Review whether your trust, charity, or entity has overseas beneficiaries
- Establish whether investments are held under a discretionary management arrangement
- Check whether more than 50% of gross income derives from financial assets
- If you are uncertain, contact your adviser as soon as possible — the earlier this is assessed, the more timey there is to prepare and file correctly
How Ballards Can Help
Our Private Client Tax team has experience supporting trusts, charities, partnerships and companies through the AEOI reporting process. We can help you assess whether a report is required, prepare and submit the return to HMRC, and ensure the right structures are in place for future compliance.
If you have trusts, charities, or other entities with discretionary managed funds and are unsure about your reporting obligations, please get in touch with our team as soon as possible ahead of the 31 May 2026deadline.
Contact us at www.ballardssllp.com or call your usual Ballards contact.
This article was prepared by Tim Lynch Private Client Tax Partner at Ballards. For specific advice relating to your circumstances, please contact our team.
Disclaimer. This article has been prepared for information purposes only. Formal professional advice is strongly recommended before making decisions on the topics discussed in this release. No responsibility for any loss to any person acting, or not acting, as a result of this release can be accepted by us, or any person affiliated with us.
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