It has been a busy week for anyone with an interest in the Trust Registration Service (TRS). On 18 October 2017 we shared with members the news from HMRC that the TRS was now live and available to agents.
As noted in that article, access to the TRS for agents is dependent on getting access to an Agent Services account. This is the new gateway for agents to access HMRC services which is being developed as part of Making Tax Digital for Business (MTDfB). It is not the same as the existing Government Gateway accounts which many agents will be familiar with. In future many more HMRC services will be provided through the Agent Services account route.
However, Agent Services is itself not fully live and is still being piloted as part of MTDfB. Consequently, we have sought clarity as to how agents who do not currently have an Agent Services account can get access to the TRS.
To the best of our knowledge at this point, agents have two options. The first is to wait until both Agent Services and hence TRS is fully accessible to all. The timing of this is as yet unspecified, and will be at best late October/early November.
The alternative is to follow the steps below, which were supplied to us by HMRC on 19 October, setting out how to request an agent services account purely for TRS purposes at this stage.
Whichever option agents choose, they should bear in mind that their Agent Services account will be the central point of contact with HMRC in the future, so it may not be appropriate for this to be set up by the trust team without consulting the wider firm. Agent Services accounts are secured by 2 Step Verification (2SV) which requires the main account to be associated to a mobile, landline or app which will need to be accessible in the future. Care needs to be taken to select an appropriate device to ensure that the firm doesn’t find an urgently needed access code going to the phone of a partner or staff member who is on holiday. Individual staff can be given access by setting up delegate access on the main account. We have written more about 2SV in the context of businesses here.
The position in relation to the TRS is clearly not satisfactory and we will continue to lobby for an extension to allow agents more time to comply with their obligations.
Member’s feedback on their experiences are welcome to atttechnical [at] att.org.uk.
Alternative access steps provided by HMRC on 19 October:
“The new TRS is now available for agents to use. As part of this online process, agents will be taken through the steps to create an Agent Services account before they can register on behalf of trustees.
Agents use the link from GOV.UK to register a trust. As part of that journey, the agent will be asked to create an Agent Services account, and the agents will be directed to request access to the Trust Registration Service by email. The agent will receive a response from HMRC giving them access to Agent Services and some guidance on what to do next. Once they have created an Agent Services account they will be directed to the Trusts Registration iform.
In registering for an Agent Services Account they will have been identified as seeking to access the TRS, and will not be offered the option of linking existing government gateway IDs and client relationships. This is only undertaken by agents participating in the controlled go live of MTDfB.”
Our understanding of these instructions is that in order to obtain an Agent Services account for the purposes of accessing TRS, the agent must first go to the link above for the TRS. Under the heading ‘Register your trust’ is a link to ‘register your trust online’. Entering (one of) the agency’s existing Government Gateway credentials here should trigger a notification that an Agent Services account is required to proceed. We understand that the system will then provide a contact email for the agent to ask HMRC for access to Agent Services for the purposes of TRS.
Agents may experience a delay before they receive a response to this email. Response times of up to two weeks have been reported to us.
The reply from HMRC should contain a link which the agent can use to set up an Agent Services account just for TRS. Other functionality which will be available via Agent Services in the future, such as importing client lists, should not be available to agents setting up accounts at this stage. This is because Agent Services is not fully live. As noted above, care should be taken in setting the Agent Services account up as we understand that, once created, this will be the main account for the agency going forwards.
Once the Agent Services account has been created, the agent can go back to the original login for TRS and should then be able to report their trusts.
In effect the agent needs to go through the following loop:
- attempt to log into the TRS with existing credentials
- be directed to contact HMRC by email to obtain a link to obtain correct Agent Services credentials
- Email HMRC
- Use link received to set up Agent Services credentials
- Return to the TRS log in and use new Agent Services credentials to commence registrations
As we understand it, the Agent Services account set up this way should acquire all the future functionality of Agent Services as it is rolled out, although we are seeking confirmation of this point.
If agents find their experience differs, please do let the ATT Technical team know and we can feed-back to HMRC.