Ireland's Central Register of Beneficial Ownership of Trusts (CRBOT): A Guide for Accountants

If you act for Irish trustees, or you carry out customer due diligence on a client that is a trust, you will come across the Central Register of Beneficial Ownership of Trusts, usually shortened to CRBOT. It is separate from the register of beneficial owners of companies, it is run by Revenue, and accountants as designated persons have specific rights and duties in connection with it. This guide summarises what Revenue and other published sources say, and flags where we could not confirm the detail. It complements our guide to the Irish register of beneficial ownership for companies and our overview of Ireland's anti-money laundering law.

What the CRBOT is

According to Revenue, the CRBOT is required by EU anti-money laundering law and aims to help prevent money laundering and terrorist financing by improving transparency on who ultimately owns and controls Irish trusts. Trustees submit the details to Revenue, which manages the register. Revenue says the CRBOT is separate from its tax and customs administration, that Revenue's tax records will not be used to update the register, and that each trust receives its own Trust Register number. Revenue lists its legal basis as the 4th and 5th Anti-Money Laundering Directives, as transposed by S.I. No. 194 of 2021 and the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021, together with later amending regulations: S.I. No. 440 of 2025 on discrepancy notice reporting and S.I. No. 335/2026.

Which trusts must register

Revenue's guidance says a "relevant trust" is an express trust established by deed or other declaration in writing, as opposed to one inferred by law from the parties' conduct. It must submit information to the CRBOT where the trustees are resident in Ireland or the trust is administered in Ireland. Revenue's page on exemptions lists subpages covering sports clubs, charities and estates, multiple member states, non-residents and excluded arrangements, but we could not read their contents, so we do not describe the exemptions here.

The Law Society Gazette, reporting a Law Society tax update on 12 March 2026, described the scope as broad: a trust may be in scope if trustees are Irish-resident, the trust is administered in the State, or a trustee enters a business relationship in Ireland. It also said only written trusts are captured and that a trust created under a will generally falls in scope. That is a report of a speaker's remarks rather than Revenue guidance, so check Revenue's non-resident guidance for any trust with a foreign element.

Deadlines and updates

Revenue says trustees must register within six months of the trust's creation, and that for trusts established on or before 23 April 2021 the deadline was 23 October 2021. The Gazette report adds, attributing it to the Law Society update, that changes to beneficial ownership information must be updated within 14 days, that registration is often needed earlier when trustees enter a business relationship with a designated person such as an accountant, and that trustees must keep an internal beneficial ownership register that matches the central filing. We did not read the regulations to confirm those last points.

Revenue's enforcement posture

The Gazette article of 16 March 2026 says Revenue's position is that all in-scope trusts should already be registered and that Revenue is moving from education to enforcement, with outreach at business premises in sectors likely to engage with the register. Revenue's own page says it runs a programme of compliance activities checking the quality of submissions, with follow-up checks in sectors where trusts are common, including the financial, sporting and charitable sectors. The article gives no compliance figures.

Your role as a designated person

Revenue's page on restricted access says a designated person, as defined in section 25 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, can access restricted CRBOT information where a trustee enters an occasional transaction with them, forms a business relationship with them, or where they are carrying out customer due diligence under Part 4 of the Act for a relevant trust. Members of the public with a legitimate interest can also apply in limited circumstances, such as where they are engaged in preventing, detecting or investigating money laundering or terrorist financing offences.

Revenue also provides a discrepancy notice form for designated persons who form the opinion that a relevant trust has not registered its trust information. The form we read covers non-registration, requires details of the trust, the basis for the opinion and each beneficial owner, applies to one trust per form, and is submitted through Revenue's MyEnquiries service. The Gazette report says that, under S.I. No. 440 of 2025, designated persons must check during customer due diligence whether trusts are registered and correctly registered, and report material discrepancies, and that failure can lead to a fine or prosecution. Because we did not read the regulation itself, treat the scope of that duty as something to confirm.

Practical steps

These are our suggestions, not Revenue guidance. When a trust becomes a client, ask for its Trust Register number, a copy of the trust deed and the trustees' confirmation of who the settlor, trustees, protector, beneficiaries and anyone else exercising effective control are. Compare that with what the register shows, and keep a note of the comparison on file. If you believe the trust has not registered, consider a discrepancy notice and take advice on your own obligations. For comparison with the UK position, see our guide to the Trust Registration Service.

What we could not confirm

• We could not read Revenue's subpages on exemptions, non-residents and excluded arrangements, so this guide does not list who is exempt.
• We did not read S.I. No. 194 of 2021, S.I. No. 440 of 2025 or S.I. No. 335/2026 directly, so the update timelines and the scope of the discrepancy duty rely on Revenue's pages and the Gazette report.
• We did not find penalty amounts stated on Revenue's CRBOT page.
• We did not read the CRBOT FAQs or the glossary, which may refine the points above.

Frequently asked questions

Does a will trust have to register?

The Gazette report says a trust created under a will generally falls in scope. Check Revenue's guidance on estates before relying on that.

Who submits the registration?

Revenue says trustees submit the details.

Where can I find more on compliance?

See our CPD courses for accountants and finance professionals.