The Association of International Life Offices (AILO) is urging advisers and trustees to check UK trusts holding Irish-issued life policies are registered on Ireland’s Central Register of Beneficial Ownership of Trusts (CRBOT) ahead of any policy transaction to avoid disruption for clients.
As of March 2025, UK trusts holding Irish-issued life policies must be registered on CRBOT prior to a transaction taking place. Previously, there were practical challenges associated with registrations, but technical solutions have now been introduced to enable non-Irish trustees to register on the Irish trust register.
Marie Hainge, chair of AILO’s legal and regulatory committee, said: “Our earlier engagement with Irish authorities focused on ensuring a workable registration process for UK and other non-EU trusts.
“With registration now possible, the focus must shift to awareness and action. Advisers should ensure their trustee clients register well before they need to transact.”
Jonathan Hall, legal executive at AILO, added: “We are particularly concerned about situations where trustees only become aware of the requirement when they attempt time-critical transactions such as policy surrenders or assignments.
“At that point, registration will need to be completed before the transaction can proceed, which could delay access to funds.”
AILO noted that some trusts, such as pension schemes, may also need to be registered even if they are exempt in the UK under the Trust Registration Service. Trusts administered in the EU are exempt from registration in Ireland, such as Malta-based QROPS schemes.
