TRS update – “digitally excluded” agents

Readers of our newswire will be well aware of the problems with HMRC’s Trust Registration Service (TRS). Our most recent news item, Are you a trustee?, provides a summary of the requirements and deadlines for registering trusts. 

HMRC has been providing us with updates on the TRS, and the most recent concerns agents who are digitally excluded. By “digitally excluded”, HMRC does not mean agents who are unable to operate online at all, but those who have been unable to access the new Agent Services Account in order to use the TRS. 

In essence – those who have an HMRC agent code should now be able to access the Agent Services Account.


The full text of HMRC’s message, explaining how to do this, is as follows: 

“We are pleased to inform you that agents who were unable to access the new Agent Services Account to register their client’s trust and/or complex estate are now able to do so using their agent code. We are sorry that a small number of agents were not able to use the service when they tried to do so, and for any inconvenience this may have caused. 

“The new Agent Services Account is being delivered iteratively and the majority of agencies have successfully registered. Unfortunately, those agencies who have no prior digital footprint with HMRC have experienced issues in opening a new Agent Services Account. 

“For agencies which attempted to register before 8 January 2018, please try again. The online service has been enhanced and you should now be able to register with Agent Services. As part of the process you will be asked to provide your HMRC agent code so please make sure you have that information before starting. 

“If it was after 8 January 2018, have you previously registered with HMRC as an agent and obtained an agent code? Options are: 

Yes, I have an agent code

You will need this and to have previously acted on behalf of a client for either Self Assessment or PAYE in order to be able to create a new Agent Services account. This may have been a paper transaction using a 64-8. If this is the case you should be able to register using your existing agent code and UTR. Please visit to register your trust online. 

I have no agent code or have never represented a client for HMRC

If you do not have any clients who are Self Assessment or PAYE customers with HMRC you will not be able to access Agent Services at the moment. 

“To be able to register for HMRC Agent Services you will require an agent code and you will need to apply for one in writing. Further guidance is available online at Once you have received your agent code you will need to be appointed as an agent for an existing Self Assessment or PAYE client. 

“For this first year of the Trust Registration Service, HMRC will not impose a penalty on the failure to register existing trusts by 31 January 2018, but no later than 5 March 2018. 

“Please note that you will require the National Insurance number of the trustees to register a trust and of personal representatives and the deceased if you are registering a complex estate, as shown on the guidance on at (trusts) and (complex estates). If you do not have the relevant National Insurance number, please follow the on-screen instructions when registering. Failure to provide this information will result in delays to the processing of your registration and the issuing of the UTR as well as requiring further contact with HMRC to provide the correct information.”

  • After wasted hours and much frustration, I finally managed to access TRS and register a trust on Sunday.  It went very smoothly this time (yippee!) but there are no on-page help bubbles to assist with answering some of the questions where the answer was not obvious to me for the trust I was dealing with so  I had to work out the answers some of the questions by trial and error.