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Privacy and reporting · Who sees what

Who can see an offshore policy, and who cannot

An offshore policy is a private contract between you and an insurer. None of the reporting it generates is published, and when the policy belongs to trustees the proceeds are paid to them under the trust, not through your will. The privacy is from the people around a family. HMRC still receives the policy's value every year and a certificate for every gain.
What each side sees
Every year
HMRC receives the policy's cash or surrender value at 31 December through the Common Reporting Standard, and a certificate for each chargeable event gain
Not published
CRS reports, chargeable event certificates and the Trust Registration Service are not public. HMRC shares TRS data only on narrow grounds
IEIM402120; ICTA 1988 s.552; TRSM60020. The matrix below sets out who sees what, and marks where the answer depends on the facts.

UK law and HMRC guidance as at 23 September 2026, for a UK-resident individual and for trustees in England and Wales.

At a glance

Private from people, visible to HMRC

01
In your own name

A portfolio held directly sits in your name at a bank or custodian. On death it passes under your will, and the will becomes a public document once probate is granted. A stake of more than 25% in a UK company puts you on the public register of people with significant control.

02
Owned through a policy

You own a contract; the investments behind it are held by the insurer. The reporting the policy creates goes to you and to tax authorities, not to the public. If trustees own the policy, the proceeds are payable to them as owners and are dealt with under the trust deed rather than the will.

03
What HMRC still sees

Nothing is hidden from HMRC. The insurer reports the policy under the CRS and issues chargeable event certificates, you enter gains on SA106, and a trust holding the bond registers on TRS. A divorce court and a trustee in bankruptcy get full details of a policy you own.

When someone comes looking

What each person or authority can find, for money held directly and for the same money inside a policy. Two of the six are no different with the policy, and one is a case the policy cannot solve.
No difference

HMRC's annual data

Held directly

A UK account appears on your tax return through the income it pays. An account with a bank abroad is reported to HMRC under the Common Reporting Standard.

Inside the policy

The insurer is a CRS Specified Insurance Company and reports the policy's cash or surrender value each year. Every chargeable event gain comes with a certificate, sent to HMRC as well where it is large.

Your will is proved

Held directly

The portfolio is part of the estate dealt with under the grant of probate. Anyone can order a copy of the probate record, including the will, about 14 days after the grant.

Inside the policy

A policy you own personally is also part of the estate. A policy owned by trustees is not yours to leave: the proceeds are payable to the trustees and handled under the trust deed, so they do not pass under your will.

A journalist or a neighbour searches

Held directly

A portfolio at a bank or custodian is not on a public register in your name. A stake above 25% in a UK company is: it appears on the Companies House register of people with significant control.

Inside the policy

Nothing in CRS reporting, chargeable event certificates or TRS is published. Nor can the policy hold your stake in your family company if you, or someone acting for you, could select it: that would make it a personal portfolio bond (ITTOIA 2005 s.516).

No difference

Your divorce

Held directly

Form E requires a full, frank and clear disclosure of your assets, with values.

Inside the policy

Form E section 2.5 asks for every life insurance policy, with its surrender value. The policy is as visible to the court as a bank account. A court-ordered assignment of it on divorce is not a chargeable event.

You are made bankrupt

Held directly

The official receiver identifies, protects and realises your assets for creditors.

Inside the policy

If you own the policy, the official receiver writes to the insurer and payments due to you go to the trustee in bankruptcy. If the benefits are held in trust for others and the trust is genuine, the official receiver has no further interest in it (paras 33.54 to 33.55).

Not solved

You own 30% of your family company

Held directly

You appear on the public PSC register, unless Companies House agrees to protect your details.

Inside the policy

The policy does not change this. If you, or someone acting for you, could select the shares for the policy, it would be a personal portfolio bond (ITTOIA 2005 s.516), so in practice the stake stays in your name.

The full list of what the insurer reports, when, and on which form is in What HMRC learns about an offshore policy. What protects the policy from creditors, and where a gift into trust can be challenged, is on the page on asset protection.

Who sees what: your own map

Choose who might be looking and how the money is held. Each answer gives what that person or authority can see and the basis for it. Where the answer depends on the facts, the cell says so.
Visibility map
Who sees what, in your situation
Who is looking
HMRCThe insurer's regulatorA UK court in a divorceThe official receiver in a bankruptcyThe publicYour family and beneficiariesSource-of-funds checks when you buy (a house, say)
How the money is held
Held directlyIn the policyPolicy held by trustees

HMRC · Held directly

What they see

Everything. UK income and gains go on your Self Assessment return. An account with a bank outside the UK is reported to HMRC under the Common Reporting Standard.

Basis

International automatic exchange of information (CRS); Self Assessment.

HMRC · In the policy No difference

What they see

The policy and its value. The insurer is a CRS Specified Insurance Company and reports the cash or surrender value at 31 December each year. Each chargeable event gain produces a certificate, sent to HMRC as well where there is an assignment for value or the gain is more than half the basic rate limit. You enter the gain on SA106.

Basis

IEIM400840; IEIM401640; IEIM402120; ICTA 1988 s.552; HS321.

HMRC · Policy held by trustees No difference

What they see

The same insurer reporting, plus the trust itself: a trust holding an investment bond must register on the Trust Registration Service. Gains are taxed on the settlor if alive and UK resident, otherwise usually on UK trustees (on a bare trust, on the beneficiary). Who appears on the CRS report depends on how the trust is classified under the CRS.

Basis

TRSM23030; ITTOIA 2005 ss.465 to 467; CRS classification of the trust.

A UK court in a divorce · Held directly

What they see

Full disclosure. You have a duty to the court to give a full, frank and clear disclosure, with values.

Basis

Form E.

A UK court in a divorce · In the policy No difference

What they see

Full disclosure. Form E section 2.5 asks for all life insurance policies with surrender values, policy numbers and any assignments. A court-ordered assignment of the policy on divorce is not a chargeable event.

Basis

Form E, section 2.5; IPTM3420.

A UK court in a divorce · Policy held by trustees Depends on the facts

What they see

Form E asks about interests under trusts, including discretionary trusts, with an estimate of value, and about assets held outside England and Wales. What the court can do with a trust interest depends on the trust and the case.

Basis

Form E, section 2.14.

The public · Held directly

What they see

Nothing, for a portfolio at a bank or custodian. A stake of more than 25% in a UK company is on the public PSC register. On death, the will becomes available to anyone once probate is granted.

Basis

Companies House PSC guidance; gov.uk probate records.

The public · In the policy

What they see

Nothing through the reporting regimes: CRS reports go to tax authorities and certificates go to you and HMRC. If the policy pays into your estate on death, it is dealt with under the grant of probate, and the will becomes a public record.

Basis

IEIM402120; ICTA 1988 s.552; gov.uk probate records.

The public · Policy held by trustees

What they see

The Trust Registration Service is not a public register. HMRC releases limited details only to someone investigating a specific case of money laundering or terrorist financing, or about a trust with a controlling interest in an offshore company. The proceeds are paid to the trustees, not through the will.

Basis

TRSM60020; gov.uk trust data requests; IHTM20012.

A map of published rules and guidance, not advice on your structure. Rows marked "No difference" are the ones where the policy changes nothing; rows marked "Depends on the facts" need your documents to answer.
Start with the HMRC row, where the policy changes nothing. If the aim is a structure HMRC cannot see, stop there, because no policy provides one. The public and trustee columns are where the policy makes a difference.
Confidential review

Who can see your structure today?

Send the policy schedule, any trust deed and the list of people who hold copies. We will map who receives what, and where it depends on documents you have not yet looked at.

Read how your information is handled before submitting. Privacy Policy.

Nothing is hidden from HMRC

Three separate channels, each set out in full in what HMRC learns about an offshore policy.
The Common Reporting Standard. An insurer that issues cash value insurance contracts is a Specified Insurance Company and so a reporting financial institution (IEIM400840). A cash value contract is one where the policyholder is entitled to a payment on surrender or termination (IEIM401640), which describes every offshore bond. The amount reported is "the cash or surrender value of the contract", normally at 31 December (IEIM402120). The insurer reports to its own tax authority, which passes the information to HMRC.
Chargeable event certificates. Offshore insurers must issue certificates on the same basis as UK insurers for policies taken out after 6 April 2000 (IPTM3210). The duty is in ICTA 1988 s.552: a certificate to the policyholder within three months, and to HMRC as well where there is an assignment for value or the gain is more than half the basic rate limit, which is £18,850 in 2026/27. An insurer whose UK policies reach £1 million of premiums must appoint a UK tax representative (s.552A).
Your own return and the trust register. Gains on foreign policies go on the SA106 foreign pages; trustees use SA904 (HS321). A trust that holds only a policy paying out on death or illness is excluded from registration, but a trust holding an investment bond used for withdrawals is not, and must register on TRS (TRSM23030).

Trusts, the will and the probate record

The practical privacy a policy gives a family is mostly about what happens on death.
Once probate is granted, anyone can order a copy of the probate record, including the will, and new records appear online about 14 days after the grant (gov.uk: search probate records). Money that passes under the will passes in public, at least as to the will's terms.
A life policy is payable "to the person who owns the policy or to some other person specified under its terms", and HMRC treats a policy settled in trust "in the same way as other settled property" (IHTM20012). If trustees own the policy, the proceeds are paid to them and applied under the trust deed. They do not pass under your will. If you own the policy yourself, the proceeds on your death form part of your estate like any other asset.
Keeping money out of the will is not the same as keeping it out of inheritance tax. Whether the trust fund is outside your estate for inheritance tax depends on the kind of trust, whether you kept any benefit, whether you survive seven years, and since 6 April 2025 whether you are a long-term UK resident. That is the subject of the page on inheritance tax and succession and of loan trusts and discounted gift trusts with an offshore bond.
The trust register does not publish what it holds. HMRC shares TRS data only where the requester is investigating a specific suspected case of money laundering or terrorist financing, or asks whether a trust holds a controlling interest in an offshore company, and even then only limited details, withheld for minors and where disclosure would create a risk of harm (TRSM60020; gov.uk: ask HMRC for information about a trust).

Courts: divorce and bankruptcy

Private does not mean out of reach of the courts. A divorce court and the official receiver both see the policy.
Divorce. Form E, the financial statement in England and Wales, requires "a full, frank and clear disclosure" and asks, at section 2.5, for all life insurance policies including their surrender values. Section 2.14 covers trust interests, including discretionary trusts, and assets held outside England and Wales (Form E). An assignment of the policy ordered by the court on divorce is not a chargeable event (IPTM3420).
Bankruptcy. The Insolvency Service's guidance tells the official receiver to recover the policy documents, write to the insurer to note its interest and ask for the surrender value; payments due to the bankrupt as policyholder go to the trustee (Technical guidance for Official Receivers, paras 33.49 to 33.50). Where the benefits are held in trust for people other than the bankrupt and the trust is genuine, the official receiver has no further interest (paras 33.54 to 33.55). Whether a gift into that trust can be reversed is a question of timing and value, covered on the page on asset protection.

What privacy does not mean

Where the privacy stops.
It does not mean secrecy from any tax authority, and a structure whose purpose depends on that is the wrong structure. Nor is the policy hidden from a court: a divorce court and a trustee in bankruptcy will see it. You will still have to explain your money when you buy a house or open an account: firms supervised under the Money Laundering Regulations may ask for the source of funds, and HMRC's guidance lists bank statements and sale documents as the kind of evidence expected (ECSH33358). A large stake in a UK company also stays on the public register of people with significant control (gov.uk PSC guidance), because a policy for a UK resident whose holder, or someone acting for the holder, could select such a stake would be a personal portfolio bond (ITTOIA 2005 s.516; see investment flexibility).
What it does mean is narrower and worth having: a contract that none of the UK reporting regimes publishes, investments held by the insurer rather than registered in your name, and, when trustees own the policy, money that reaches your family under the trust rather than through a public will. How the policy is taxed is on the page on tax efficiency.

Privacy and reporting questions

Is an offshore bond confidential in the UK?

From the public, largely yes: the policy is a contract with the insurer, and the reporting it creates goes to you and to tax authorities, not to any public register. From HMRC, no. The insurer reports the policy under the Common Reporting Standard every year, issues chargeable event certificates, and you report gains on SA106.

Does HMRC know about my offshore bond?

Yes. The insurer is a CRS Specified Insurance Company and reports the policy's cash or surrender value, normally at 31 December, to its home tax authority, which exchanges it with HMRC (IEIM402120). Chargeable event certificates go to you within three months, and to HMRC as well where the gain is more than half the basic rate limit or there is an assignment for value (ICTA 1988 s.552).

Can anyone else look up whether I own a policy?

Not through the reporting regimes: CRS reports, chargeable event certificates and the Trust Registration Service are not published. The policy can come to light in court proceedings, such as a divorce or a bankruptcy, and, if it pays into your estate on death, through the administration of the estate under a grant of probate.

Does a policy written in trust stay out of my will?

Yes, if the trustees own the policy. Proceeds are payable to the owner of the policy, and HMRC treats a settled policy like other settled property (IHTM20012), so the money is applied under the trust deed rather than passing under your will. Whether it is also outside your estate for inheritance tax is a separate question that depends on the trust, the gift and your residence history.

Is the Trust Registration Service public?

It is not. HMRC shares TRS information only in limited cases: with someone investigating a specific suspected case of money laundering or terrorist financing who meets HMRC's conditions, or about a trust with a controlling interest in an offshore company. Even then it releases only limited details and withholds them for minors and where disclosure would create a risk of harm.

Do I have to disclose the policy in a divorce?

You do. Form E requires a full, frank and clear disclosure and asks, at section 2.5, for every life insurance policy with its surrender value. Interests under trusts, including discretionary trusts, go in section 2.14. A court-ordered assignment of the policy on divorce is not a chargeable event (IPTM3420).

What happens to the policy if I am made bankrupt?

If you own it, the official receiver recovers the documents, notifies the insurer and asks for the surrender value, and payments due to you go to the trustee in bankruptcy. If the benefits are held in trust for other people and the official receiver is satisfied the trust is genuine, it has no further interest in the policy (Technical guidance for Official Receivers, paras 33.49 to 33.55).

Will my bank or solicitor ask about the policy when I buy a property?

They may. Firms supervised under the Money Laundering Regulations must understand where the money for a transaction comes from where their risk assessment calls for it. For money from a policy, expect to show the insurer's payment confirmation and possibly how the premium was funded. HMRC's guidance lists bank statements and sale documents as examples of evidence (ECSH33358).

PPLI.com is not authorised by the Financial Conduct Authority and does not give personal advice. This is general information about UK law, not an invitation or inducement to enter into any insurance or investment contract. Policies issued by insurers outside the UK are not protected by the Financial Services Compensation Scheme.

Sources and authorities

Read as at 23 September 2026 for the tax year 2026/27. These are the rules as written; how they bear on a given policy depends on its terms and on your facts.
Last updated: 23 September 2026. Corrections are made under our editorial standards.

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Eldar Edmond Grady
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Eldar Edmond Grady
CEO, PPLI.com
Checked against UK primary sources. The statutes, HMRC manual paragraphs and regulator pages cited are linked in the text so each statement can be read beside its basis.
Last updated: 23 September 2026
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