You may recall that our latest update on the Trust Registration Service was issued to clubs/counties in February 2024 within Club Together/County Update, as below: “To follow up on earlier updates to clubs regarding the Trust Registration Service (TRS), we have received an update from the Sport & Recreation Alliance (SRA) regarding its application to sport and recreation. The SRA wrote to Treasury Ministers to outline its concerns, shared by Bowls England and other national bodies, over the potential impact of TRS requirements on sport and recreation organisations – particularly at the grassroots – and to seek the opportunity to explore further options for reform. Following this engagement, the SRA has been made aware that the Government intends to consult on potential changes to the regulations underpinning TRS. A key part of this consultation will be to ensure that the scope of TRS is effectively targeted and, as part of this, officials have committed to taking further representations from SRA on the application of TRS to sport and recreation. Against this background, the SRA has decided to delay the publication of its guidance until it has clarity on any potential changes to TRS requirements. The SRA will provide a further update to Bowls England once the Treasury consultation is published.”
The SRA has now provided further update to its member organisations as follows: “You will recall Government ran a consultation on proposed changes to the Money Laundering Regulations – including TRS requirements – back in 2024. Specifically it proposed a de minimis exemption from registration which we hoped would exempt many small unincorporated sports organisations. Following a lengthy delay, Government has recently published the outcome of this consultation here. Despite our collective representations making the case for a specific exemption for grassroots sports clubs and similar organisations, HMRC has decided to take forward a modified version of its original proposal for a de minimis exemption based on a set of tightly defined criteria, notably the exemption will only apply to trusts that meet all of the following:
• are not liable for relevant UK taxes,
• do not own or have an interest, (whole or in part), in UK land or property,
• do not exceed £10,000 in the value of accumulated assets held,
• do not have more than £5,000 in income per annum, and
• do not have more than £2,000 of “appreciable” non-financial assets (art, jewellery, antiques etc.).
This de minimis exemption will be introduced via an amendment to the Money Laundering Regulations but will not be retrospective, only applying to new trusts created on or after the date the exemption comes into force. Our initial view is that this proposed de minimis exemption is unlikely to be of much assistance to grassroots clubs or other similar sports organisations which have trust arrangements in place.
SRA next steps
We are continuing to engage with HMRC on the consultation outcome and HMRC’s proposed approach to implementation. We are also in the process of reviewing and updating our guidance for NGBs on TRS which will reflect the consultation outcome on the de-minimis test and the requirements on clubs and other sports organisations where trust arrangements exist or are deemed to exist. We are intending to move as quickly as possible on this work with a view to being able to issue this guidance in the autumn.”
In light of the SRA statement Bowls England will continue to update you as and when any new information is available.