Holding Money in Trust: Must You Still Send PIDM Details Every March?

checklist

Your trust-account document pack

1. Opening file: keep the statement that the money is held in trust, the trustee's identification details and the beneficiary details supplied to the bank.
2. Beneficiary schedule: identify each person entitled to the money and the amount or percentage belonging to that person; keep it updated as interests change.
3. Request file: keep any PIDM or bank request, its stated requirements and your submission acknowledgement. Do not assume deletion of the annual rule cancels a specific request.
4. Old reminder: if a letter cites an automatic 31 March annual obligation, ask which current legal provision or separate bank requirement it relies on.

Why this matters

Why this matters: holding money for someone else creates a different paperwork question from managing your own savings. In these regulations, a trustee is the depositor holding a trust account; a beneficiary is the person whose money is held in it. The current definition requires each beneficiary and their amount or percentage interest to be identifiable.

An old checklist can be misleading even if it was correct when issued. The original 2012 regulations required a trustee acting for two or more beneficiaries to make an annual disclosure. Today, that recurring statutory requirement has been deleted. The useful distinction is between an obsolete annual filing and the opening information or updated records that still matter.

What the law says

What changed: the original regulation 4 required disclosure on or before 31 March of every assessment year. A 2020 amendment added flexibility for another date specified by PIDM. Then the 2022 amendment deleted regulations 4 and 5, removing both that annual disclosure provision and the related bank-notification provision. The 2022 instrument expressly commenced on 1 July 2022; it was not merely a proposal.

What remains at opening: under the replacement regulation 3(1), an ordinary trustee must give the deposit-taking member a statement that the deposit is held in trust; the trustee's name, address and identity-card or passport number, or another acceptable identification; and the beneficiary's details. Those details mean each beneficiary's name and address, or a code or identifier, plus their amount or percentage interest. This guide concerns these ordinary trust accounts, not the separate opening rules for an e-money scheme.

What remains afterwards: regulation 7 allows PIDM to require information at any time, either for submission to PIDM itself or to the relevant deposit-taking member. The 2022 amendment specifically added beneficiary details and beneficiary records updated from time to time. Removing an annual filing date therefore does not remove the need for a usable, current record of who owns what.

Missing opening information is not something to dismiss as a minor administrative gap. Replacement regulation 3(3) says a trustee who later supplies the required information and documents is deemed to open a new trust account on that submission date. The practical lesson is to correct omissions promptly and preserve the acknowledgement, rather than assume a later correction automatically establishes the earlier position.

How does this impact me?

Hypothetical scenario — an outdated reminder: a trustee for two adult beneficiaries finds an old form saying an annual disclosure must be sent by 31 March. The trustee should not rely on that form as a statement of current PIDM law. A sensible written question to the bank is: 'Please identify the current provision or separate account requirement behind this request, and confirm the information you need.' This is suggested wording, not an official form or a reason to ignore the bank.

Hypothetical scenario — changing shares: an ordinary trust account was opened with the required disclosures, but the beneficiaries' respective entitlements later change under the trust arrangement. The absence of an automatic annual return is not permission to leave the beneficiary schedule stale. Keep the current entitlement record and the documents explaining the change, ready for a request. This is record-keeping advice drawn from the updated-record requirement, not a ruling that the change itself is legally valid.

Hypothetical scenario — you are the beneficiary: ask the trustee to confirm that the ordinary opening disclosure was made and that your entitlement is recorded accurately. You do not need to turn this into a demand for another beneficiary's personal information. The point is to check the record relating to your own interest; this guide does not decide access rights under the trust deed.

Key lessons

Key lesson: separate three questions — what had to be supplied when the account opened, what records must remain current, and what a particular request now requires. 'No annual return' answers only the recurring-filing question. Keep the opening disclosure, a current beneficiary schedule, supporting change documents and request acknowledgements together so that a specific request does not become a reconstruction exercise.

Bottom line

Bottom line: do not treat an old 31 March checklist as the current annual PIDM obligation. Equally, do not confuse removal of that obligation with permission to keep incomplete trust-account records. Check the current request, correct opening omissions and maintain an identifiable record of each beneficiary's interest.

Detailed steps

• Find the account-opening disclosure and bank acknowledgement; check the trust statement, trustee identification and beneficiary details against the ordinary opening rule.
• Keep an updated beneficiary schedule showing names and addresses or identifiers, and each amount or percentage interest; retain documents supporting changes.
• If a request arrives, keep the exact notice and ask whether it is a PIDM request or a separate bank requirement. Follow the verified request rather than assuming an old annual deadline applies.
• If opening details were missing, ask the bank how to supply the required information and retain proof of submission; seek advice if the effective date of the trust-account treatment matters.