In 2025, STEP’s policy and technical work delivered significant legislative and regulatory outcomes across the globe. Through expert engagement and strong collaboration with policymakers, STEP has helped shape law reform, improve fiduciary practice and protect families and beneficiaries worldwide.

Trust reform in Bermuda

As part of STEP’s positive impact trust reform work we continue to advocate for trust law that reflects modern economic, social and environmental realities. In September, Bermuda’s House of Assembly approved two landmark pieces of legislation drafted by STEP:

• The Trustee Amendment Act 2025 and
• The Benefit Entities Act 2025.

These reforms modernise fiduciary duties and explicitly recognise that responsible and sustainable investing can be compatible with trustees’ obligations. The Trustee Amendment Act 2025 represents a significant advance in global trust law, reinforcing responsible stewardship of wealth and positioning Bermuda as a leader in modern fiduciary practice.

Modernising wills law (England and Wales)

STEP played a pivotal role in shaping the England and Wales Law Commission’s proposals to modernise wills law. STEP provided confidential feedback on the draft Wills Bill. Many of our technical recommendations were incorporated into the final legislation, which was published in May alongside the Law Commission’s report Modernising Wills Law.

The draft legislation is currently being reviewed by government ahead of implementation, marking a major step towards a modernised and more accessible wills framework in England and Wales.

Financial Action Task Force (FATF)

STEP contributed directly to the FATF’s global report, Comprehensive Update on Terrorist Financing Risks, published in July. We liaised with the Home Office and provided expert insight on how trusts may be misused or vulnerable to terrorist financing, informing the final report.

In addition, STEP developed and delivered a dedicated member survey for the UK’s HM Treasury – the National Risk Assessment Private Sector Questionnaire. The survey findings were incorporated into the FATF report, ensuring the trust and estate sector’s perspective was accurately represented at an international level.

UK Budget: influencing tax and estate administration reform

STEP successfully advocated for several legislative changes announced in the UK Budget:

• Transferable APR and BPR allowances: From 6 April 2026, any unused portion of the GBP1 million allowance available under the 100% rate of agricultural property relief (APR) and business property relief (BPR) will become transferable between spouses and civil partners.
  Improved IHT administration for pension assets: From 6 April 2027, new rules will support personal representatives (PRs):
  • PRs may instruct pension scheme administrators to withhold up to 50% of taxable benefits for up to 15 months to ensure inheritance tax can be paid where required.
  • PRs will be discharged from liability for inheritance tax on pension funds discovered after HMRC clearance has already been granted.

These changes reflect long-standing STEP policy positions and will significantly improve fairness and administrative clarity for families and practitioners.

• The Infected Blood Scandal – securing tax justice: In April, STEP launched a joint campaign with the Association of Lifetime Lawyers calling on HMRC to amend secondary legislation so that compensation payments under the Infected Blood Scandal scheme would not be subject to inheritance tax.

The campaign was successful: the Chancellor confirmed during the Budget that these payments will be exempt from inheritance tax. HMRC has since contacted STEP to discuss the legislative process, ensuring families affected by the scandal are not further disadvantaged.

Hague Trusts Convention: international policy impact

STEP’s international policy expertise was recognised through its collaboration with the Hague Conference on Private International Law (HCCH). Following discussions initiated in 2024, STEP contributed to a project reviewing post-Convention developments and future work relating to the 1985 Hague Trusts Convention.

STEP provided direct technical feedback and produced a member survey covering six jurisdictions, identifying similarities between common law trusts and civil law equivalents to improve cross-border understanding under EU law. The HCCH published these findings in the 1985 Trusts Convention Report, which refers to STEP as a key stakeholder and expert.

Looking ahead to 2026

2026 will bring yet more impact. We hope to see more jurisdictions embrace positive impact trust reform, and we will continue to influence policies globally to ensure they are workable and effective.

One important piece of work that we will be launching early in 2026 is guidance for jurisdictions on their approach to defining ‘legitimate interest’ with respect to accessing beneficial ownership information.

Globally, we know that many jurisdictions are grappling with this issue – trying to find the right balance with regard to transparency objectives and privacy concerns. So we are currently working on developing a practical checklist for policymakers, taking insights from a range of jurisdictions and highlighting key considerations such as privacy and security, fair access and standards harmonisation. The idea is that this would provide a consistent framework for jurisdictions and better align approaches in this area.

You can find out more about this initiative at our webinar taking place on 28 January: Legitimate interest: Striking the essential balance between transparency and safeguards

Updated 23 December: The UK government announced that from 6 April 2026 the allowance for 100% relief of agricultural property relief (APR) and business property relief (BPR) will be increased from GBP1million to GBP2.5million. This means that a couple will now be able to pass on up to GBP5 million of agricultural or business assets between them, on top of the existing allowances such as the nil rate band. We are delighted by this announcement and pleased that STEP expertise has contributed to this significant change to the policy.

If you would like to talk to us about any of the above initiatives, or you would like our assistance with any upcoming policy projects, you can contact us at policy@step.org

Emily Deane TEP Technical Counsel & Head of Government Affairs