Most trusts for pure protection plans that don’t have a surrender value do not need to be registered with HMRC when they are first set up. They would only need to be registered if there is a claim, the plan is surrendered, or the trust has a tax liability.
For claims on death, if the trustees pay the benefits out to a beneficiary within 2 years of the date of death, the trust doesn’t need to be registered. For all other claims, if the trustees instruct us to pay the benefit direct to a beneficiary, the trust doesn’t need to be registered. But if payment is made to the trustees, the trust must be registered within 90 days of the day the claim is paid, even if the trustees pay the benefit to a trustee within this period.
If the policy can acquire a surrender value, such as some older unit-linked whole of life plans, the trust doesn’t need to be registered until the policy is surrendered or there is a claim as above.