Thousands of UK trusts may now be in breach of Irish law, according to Dains Ireland, as a little-known rule change quietly took effect earlier this year. Ireland’s Central Register of Beneficial Ownership of Trusts (CRBOT) became mandatory for non-resident trusts on 5 March 2025, but many trustees and advisers remain unaware of its scope or urgency.

The register applies to any UK or non-EU trust that holds Irish property or maintains an ongoing relationship with an Irish-based provider—including financial advisers, brokers, or life assurance companies. Without registration, no new policies can be issued, and many existing transactions will grind to a halt.

“We’re seeing a pattern now,” said Rachel Murphy, Tax Partner at Dains Ireland.
“UK trustees go to activate a policy, or a client decides to sell a bond, and suddenly it all stalls. The trust has a connection to Ireland, but no one has heard of CRBOT. They’re stuck until it’s registered.”

Rachel explained that this is catching out many financial advisers and trustees who work cross-border. The UK’s Trust Registration Service (TRS) has been live since 2017, but it does not cover Irish compliance requirements. The two systems are separate, and one does not replace the other.

“This is not duplication for the sake of it,” said Rachel. “It’s a legal requirement under Irish law, and it’s part of a broader EU effort to bring greater transparency to the ownership and control of trusts. The problem is, the information sits in silos. Many UK firms haven’t made the connection between the two regimes.”

More trusts affected than expected

According to HMRC, over 733,000 trusts were registered in the UK as of March 2024, with 115,000 new trusts added in the previous 12 months alone. Many of these are now using Irish-based investment products or property structures. Rachel says the knock-on effect is significant.

“We’ve worked with UK-based advisers who thought they were fully compliant. But the moment we ask whether the trust holds an Irish-issued bond or an insurance policy from an Irish provider, the penny drops.
These are routine products in financial planning. And yet they tip the trust into CRBOT territory.”

What’s required for CRBOT?

Trustees must submit details for each beneficial owner, including name, address, nationality, date of birth, PPS number or equivalent ID, and a statement of the nature and extent of their interest or control.

Beneficial owners include not only the beneficiaries but also the settlor, trustees, protector, and anyone with control over the trust. For new trusts, registration must take place within six months of creation. Existing trusts must register before transacting further.

Rachel stressed that the process is manageable with the right support. Much of the required information already exists for UK-registered trusts.

“We don’t need to reinvent the wheel,” said Rachel.
“If you’ve already registered the trust with HMRC, you probably have eighty to ninety percent of the information needed for CRBOT. What we do is bridge the gap—format it properly, complete the Revenue agent link, and file it in line with Irish rules.”

For an Irish CRBOT registration the trustees do however need to provide physical proof of identity for each named party with an interest in the trust such as a copy of a valid passport or proof of a tax identification number such as a national insurance number which is not required under the UK Trust Registration Service.   

Real consequences for delay

Rachel pointed out that this is more than just a paperwork issue. Revenue has enforcement powers. Financial institutions have obligations. Trustees who fail to register can face delays, regulatory scrutiny, penalties, and in serious cases, prosecution. 

“Irish-based providers have a duty to pause or refuse transactions if CRBOT is not in place. So it is not simply a box to tick later,” she said.
“It can delay a property deal, block a bond surrender, or hold up inheritance planning. We’ve seen it happen.”

She added that transparency watchdogs such as Transparency International Ireland have highlighted persistent gaps in asset ownership visibility across Europe, especially in structures like trusts and limited partnerships. CRBOT is Ireland’s response—and it is now live and active.

“If you advise UK clients with Irish ties, you need to act now. This affects family trusts, investment structures, and estate planning tools. We can help, but don’t wait until something gets stuck.”

Support available from Dains Ireland

Dains Ireland is currently acting as agent for a growing number of UK and international trustees. The firm offers a complete CRBOT filing service, including preparation, submission, and liaison with Revenue. Trustees simply need to complete a one-page authorisation form and supply existing trust data.

“We’ve made the process as straightforward as possible,” said Rachel.
“Our role is to reduce friction, keep clients compliant, and ensure transactions aren’t delayed. We’re across both the UK and Irish regimes and can navigate the nuances quickly.”

Need help with CRBOT registration?
Contact Rachel Murphy or John Fitzgerald at Dains Ireland:

Rachel Murphy
Tax Partner
📧 rmurphy@dains.ie

John Fitzgerald
Tax Partner
📧 john.fitzgerald@dains.ie

Editor’s Notes:

• CRBOT was introduced under Irish legislation (SI 194/2021) in line with EU anti-money laundering directives.
• It applies to any trust with a business or property connection in Ireland.
• A business relationship includes ongoing arrangements with designated persons such as Irish-based banks, brokers, law firms, or insurers.
• UK TRS registration does not remove the need to register with CRBOT if there is an Irish link.

For more information, visit www.revenue.ie/en/crbot.

About Dains Ireland

Dains Ireland, formerly McInerney Saunders, is a full-service accountancy and advisory firm supporting businesses across Ireland. Now part of the Dains Group, the firm is focused on growth, innovation and delivering expert, relationship-led advice to clients navigating an increasingly complex business landscape.