Changes to the Trust Registration Service – Guidance for Unincorporated Clubs

Changes to the Trust Registration Service: Guidance for Unincorporated Clubs

It has recently been brought to Swim England’s attention that unincorporated clubs may need to register for HMRC’s Trust Registration Service (TRS).

Upon receiving the information earlier this month we have been working to understand the regulation and requirement around this to gain a clearer understanding.

If your club is unincorporated and holds property or assets by trustees then it is essential you understand the changes that are happening. For the purposes of The Trust Registration Service (TRS), Custodians of club bank accounts could be regarded as trustees.

The Sport and Recreation Alliance has recently released some guidance on the matter. Swim England is currently investigating how this could affect clubs and we intend to issue a full update shortly after a meeting with Sport England on 9th September.

As outlined in the Sport and Recreation Alliance guidance, unincorporated sports clubs and associations have no separate legal capacity so their property and assets must be held by individuals. This will be the case for property, bank accounts, intellectual property and equipment. Even if a bank account is registered in the club’s name, the Custodians of that bank account could be regarded as trustees for TRS purposes.

What clubs need to do

Clubs may wish to consider preparing information that is required for TRS registration. A full list of those details can be found on HMRC’s website.

Clubs may wish to seek their own advice on the matter and have access to the legal advice helpline on the following link –

We will provide an update following the Sport England meeting.

Is there a deadline?

The deadline given for registration is 1st September 2022. Swim England has only recently been made aware and we appreciate our full update will come shortly after the deadline for registration. We are currently working with Sport England and relevant advisors to gain a clear understanding about which clubs need to register for TRS. This will be shared as soon as possible.


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