Nevada Trustee Accountings
Part of my Nevada Trusts Guide.
By Ronald W. Brilliant, Attorney at Law · Licensed in Idaho, Nevada & California · Last reviewed: September 2026 against Nevada Revised Statutes chapters 153, 162B and 163 through 166A (current through the 2025 legislative session)
In This GuideNevada TrustsTopic 5 of 10: Trustee Accountings
An account is a report prepared by a trustee on the financial condition of the trust estate (NRS 165.020(1)(a)). Nevada’s rules on trust accounts are in chapter 165 of the Nevada Revised Statutes, known as the Uniform Trustees’ Accounting Act (NRS 165.010). The trustee of a nontestamentary trust (a trust created and taking effect during the settlor’s lifetime) has a duty to account under those rules (NRS 163.0016, 165.1204(1)). The trustee of a testamentary trust (a trust created by the terms of a will) must also account under chapter 165 (NRS 163.0018, 153.041).
This page explains who can receive an account, how to ask for one, what an account must contain, when it becomes final, and what happens if a trustee does not account. It matters to trustees who must comply and to beneficiaries who want information about the trust.
Which Trusts Are Covered
Chapter 165 applies to trusts as defined in NRS 163.020, testamentary trusts and nontestamentary trusts (NRS 165.020(1)(k)). It does not apply to certain arrangements, including resulting trusts, constructive trusts, business trusts that issue certificates of beneficial interest, investment trusts, voting trusts, insurance trusts before the insured’s death, and liquidation trusts, among others listed in the statute (NRS 165.020(2)). It does apply to charitable trusts, and documents required to be delivered to beneficiaries of charitable trusts must be delivered to the Attorney General (NRS 165.230).
For a testamentary trust, unless the will or a court order provides otherwise, the trustee must account in the same manner as the trustee of a nontestamentary trust until the trust ends (NRS 165.1201(2)). A court with jurisdiction over a testamentary trust may also order the trustee to account, on good cause, to the persons and in the manner the court orders (NRS 153.041).
Who Is Entitled to an Account
The trustee of a nontestamentary trust satisfies the duty to account by delivering an account in the form and manner, and to the persons, the trust instrument requires (NRS 165.1204(2)). To the extent the trust instrument does not provide otherwise, the trustee must deliver an account, on demand, to each current beneficiary and each remainder beneficiary (NRS 165.1207(1)(a)). A trustee is not required to account to a remote beneficiary under that section (NRS 165.1207(1)(a)).
- Current beneficiary: a distribution beneficiary to whom, or for whose benefit, the trustee is authorized or required to make distributions of income or principal at any time during the accounting period (NRS 165.020(1)(d)).
- Remainder beneficiary: a beneficiary who will become a current beneficiary on the death of an existing current beneficiary or on some other event that may occur during the beneficiary’s lifetime (NRS 165.020(1)(f)).
- Remote beneficiary: a person or entity whose interest comes after the interests of one or more current beneficiaries and one or more remainder beneficiaries, all of which must end before the remote beneficiary may become a current beneficiary (NRS 165.020(1)(g)).
Exceptions
A trustee may satisfy the duty to account under the following rules, where they apply (NRS 165.1207(1)(b)):
- Revocable trusts: while the settlor can revoke the trust, the trustee need not account to anyone other than the settlor. The exceptions are when a court-appointed guardian of the settlor’s estate, or another person with the right of revocation, demands an account for the settlor, or when a court finds under NRS 164.015 that the settlor or other holder of the right of revocation is incompetent or susceptible to undue influence and orders an account.
- Broad power of appointment: while the trust is irrevocable but subject to a broad power of appointment, the trustee need account only to the power holder for the part of the trust subject to that power.
- Eliminated beneficiaries: no account is required to a person eliminated as a beneficiary by the effective exercise of a power of appointment.
- Unrelated portions: no account is required of any portion of the trust that does not affect the beneficiary’s interest, and the trustee may redact those portions.
- Discretionary interests: no account is required to a beneficiary of an irrevocable trust while that beneficiary’s only interest is a discretionary interest as described in NRS 163.4185.
- Waiver: no account is required to a beneficiary who has waived, or is deemed to have waived, the right under NRS 165.121. If the waiver is partial or only as to form, the trustee must account according to the waiver’s terms.
A trustee may petition the court for instructions about who is entitled to an account and what the trustee must do (NRS 165.1207(2)). Revocable trusts are discussed further on the Revocable Trusts page.
Requesting a List of Trust Assets
An interested person to whom the trustee must account may give the trustee a written request for a list of the trust assets known to the trustee. The request may be made at any time 60 days or more after the trustee’s appointment (NRS 165.030). The trustee must serve the list, in the manner required for notice under NRS 155.010, within 15 days after receiving the written request (NRS 165.030).
Demanding an Account
Notwithstanding any contrary provision in the trust instrument, but subject to the exceptions above and the trustee’s right to petition for instructions, a trustee must provide an account that meets NRS 165.135 to a beneficiary who demands one under NRS 165.141 (NRS 165.138(1)). A beneficiary who has not otherwise been provided an account may send the trustee, or the trustee’s attorney of record, a written demand that includes (NRS 165.141(1)):
- The demanding beneficiary’s identity, including the mailing address of the beneficiary or the beneficiary’s attorney;
- The accounting period for which an account is demanded; and
- The nature and extent of the account demanded and the legal basis for the demand.
The demand and the trustee’s response must be delivered by first-class mail, personal delivery or commercial carrier (NRS 165.141(3)). Within 14 days after receiving the demand, the trustee must notify the beneficiary that the trustee accepts it, rejects it, or intends to seek instructions from the court (NRS 165.141(2)). Then:
- If the trustee accepts, the trustee must provide the account within 60 days after receiving the demand, unless that time is changed by the beneficiary’s consent or by court order (NRS 165.141(2)(a)).
- If the trustee rejects, the notice must give the grounds and tell the beneficiary that he or she has 60 days to petition the court to review the rejection (NRS 165.141(2)(b)).
- If the trustee seeks instructions, the trustee must file a petition under NRS 164.015 within 15 days after receiving the demand (NRS 165.141(2)(c)).
If the trustee does none of these things as required, the demand is deemed rejected (NRS 165.141(4)). A beneficiary may not demand an account for an accounting period that is already deemed final under NRS 165.1214(4) (NRS 165.141(5)).
On a demand under NRS 165.141 by a beneficiary entitled to an account, the trustee must provide a copy of the trust instrument, except as the trust instrument expressly provides otherwise (NRS 165.147(1)). The court may direct the trustee to provide an entitled beneficiary a copy of the trust instrument, or pertinent portions, notwithstanding any contrary trust provision (NRS 165.147(2)).
A trustee may also, at the trust’s expense, provide an account to beneficiaries at any time, with or without a demand, and give beneficiaries more information than the trust instrument or law requires (NRS 165.138(2)).
Timing and Delivery
Except as the trust instrument or a court order requires otherwise, the trustee must deliver a required account within 90 days after the end of the accounting period (NRS 165.1214(1)). That time may be extended by the beneficiary’s consent or by court order for good cause (NRS 165.1214(1)). Except as the trust instrument requires otherwise, a trustee need not provide an account more than once in any calendar year unless a court orders it on good cause (NRS 165.1214(3)).
A trustee is deemed to have provided an account to a person when a copy is delivered as a court order directs or, if there is no order, by certified, registered or ordinary first-class mail, by overnight delivery through a recognized delivery service, by personal delivery, or by email or a secure website if the statute’s requirements are met (NRS 165.1214(2)).
What an Account Must Contain
An account must include (NRS 165.135(1)):
- A statement of the accounting period;
- For trust principal: what was held at the start of the period, in what form, and its approximate market value; additions, with dates and sources; investments collected, sold or charged off; investments made, with date, source and cost; deductions, with date and purpose; and principal on hand at the end, with its approximate market value;
- For trust income: income on hand at the start and in what form; income received, when and from what source; income paid out, when, to whom and for what purpose; and income on hand at the end and how it is invested;
- A statement of unpaid claims, with the reason for not paying them; and
- A brief summary of the account, in substantially the form set out in the statute (NRS 165.135(2)).
Instead of reporting income and principal separately, the trustee may combine them, as long as the combined report does not materially impede a beneficiary’s ability to evaluate the charges and credits against his or her interest (NRS 165.135(3)). An account may instead consist of a statement of the accounting period plus a compilation or financial statement of the trust prepared by a certified public accountant that summarizes the required information, or a statement prepared by the trustee that the trustee and the person receiving it agree is sufficient (NRS 165.135(4)). An account prepared under that alternative must be in writing, signed by the person receiving it and delivered to the trustee (NRS 165.135(4)).
Except as otherwise ordered by the court, the cost of preparing an account is paid from the trust estate (NRS 165.1214(6)). An attorney for a trustee is entitled to reasonable compensation, allowed by the court, for preparing and presenting intermediate and final accounts (NRS 165.210(2)).
When an Account Becomes Final
An account is deemed approved and final (NRS 165.1214(4)):
- As to a beneficiary who received a copy, if no written objection is delivered to the trustee within 90 days after the date the trustee provided the account to that beneficiary;
- As to beneficiaries not required to receive an account (such as nonvested, contingent, remote, minor, unborn or unknown beneficiaries), if it is deemed approved and final by a beneficiary with a similar but preceding interest under NRS 164.038, and as to any beneficiary who waived an account under NRS 165.121;
- By a trust adviser or trust protector, if notice to beneficiaries was waived or modified under NRS 163.004 or the trust instrument authorizes it; and
- By all parties to a nonjudicial settlement agreement under NRS 164.940(3)(f).
If an account is submitted to the court for approval by a petition under chapter 164, it is final and approved by the court’s order, subject only to an interested person’s right to appeal (NRS 165.1214(4)). Absent fraud or intentional misrepresentation, once an account is deemed approved and final, the trustee is released and discharged from all liability to the beneficiaries for whom it is deemed approved and final, as to all matters set forth in the account (NRS 165.1214(5)).
Waiving the Right to an Account
Any beneficiary may waive the right to receive an account by delivering a signed waiver to the trustee (NRS 165.121). The waiver may be limited to the form of the account, the right to seek a hearing on the account, or the right to notice of a hearing (NRS 165.121). It also applies to beneficiaries the waiving beneficiary represents under NRS 164.038 or by court order (NRS 165.121).
Separately, a beneficiary of full age and sound mind, acting on full information, may by written instrument delivered to the trustee excuse the trustee, as to that beneficiary, from any chapter 165 duty, or exempt the trustee from liability to that beneficiary for failing to perform it (NRS 165.170).
If the Trustee Rejects a Demand
A beneficiary whose demand complying with NRS 165.141 is rejected, or deemed rejected, must file a petition for court review within 60 days after the rejection date, and is afterward barred from demanding an account for that period (NRS 165.143(1)). The rejection date is the date the trustee gives notice of rejection or, if the trustee neither accepts nor rejects, 14 days after the beneficiary delivered the demand (NRS 165.143(2)). If the court has not already taken jurisdiction over the trust, the beneficiary must also petition under NRS 164.010 to confirm the trustee’s appointment and bring the trust under the court’s jurisdiction, and may combine the two petitions (NRS 165.143(3)).
Notice of the hearing must be given to all interested persons as provided in NRS 155.010 (NRS 165.143(4)). At the hearing, the court may order the trustee to provide an account, declare that the petitioner is not entitled to one, or order an account together with an independent review (NRS 165.143(6)). Except as provided in NRS 153.031(3), each petitioner pays his or her own expenses, including attorney’s fees (NRS 165.143(7)).
Confidential Accounts
If, while considering a petition under NRS 165.143, the court finds the beneficiary is entitled to an account but the trust instrument authorizes or directs the trustee not to provide one, the court shall, on the beneficiary’s request, compel the trustee to provide an account confidentially (NRS 165.145). The account goes to the court and to one or more reviewers chosen by the beneficiary, each of whom must be a certified public accountant or an attorney (NRS 165.145(2), (3)). The beneficiary pays for the reviewers, subject to NRS 165.145(5)(b), while the cost of preparing the account is a trust expense (NRS 165.145(4)).
Each reviewer prepares a written report for the court, filed under seal or submitted for in camera review, and delivers a copy to the trustee (NRS 165.145(5)(b)). The trustee may object within 10 days after receiving the report (NRS 165.145(6)). If the court finds the trust, as it affects the beneficiary, has not been or may not have been properly administered or accounted for, the court shall enter an order granting the relief needed to protect the beneficiary’s interests or allow the beneficiary to enforce his or her rights (NRS 165.145(6)).
Enforcement and Consequences
- Personal liability: unless the court determines the trustee acted in good faith, a trustee who fails to provide a required account is personally liable to each person entitled to an account who demanded it in writing, for all costs reasonably incurred to enforce the trust or chapter 165, including reasonable attorney’s fees and court costs (NRS 165.148(1)). The trustee may not use trust funds to pay that personal liability (NRS 165.148(1)).
- Petition for instructions: if the failure to account is based on good cause due to reasonable uncertainty about the beneficiary’s right to an account, or on a trust provision that restricts or prohibits accounting, the trustee may, at the trust’s expense, petition the court for instructions (NRS 165.148(2)).
- Court orders: a beneficiary may petition the court for an order requiring the trustee to perform chapter 165 duties (NRS 165.190). A court that learns a trustee under its jurisdiction has failed to perform a chapter 165 duty shall issue a citation or order requiring the trustee to perform it (NRS 165.150).
- Penalties: when a trustee fails to perform a chapter 165 duty, the court in its discretion may remove the trustee, reduce or forfeit the trustee’s compensation, or impose another civil penalty (NRS 165.200).
Chapter 165 does not limit a court’s power to require a trustee to file an inventory, account, exhibit trust property, or give beneficiaries information or access to trust records at other times, or its power to excuse a trustee from chapter 165 duties for cause shown (NRS 165.180). A trustee or beneficiary may also petition the court to settle accounts and review the trustee’s acts, or, subject to chapter 165, to compel the trustee to report information or account to the beneficiary (NRS 153.031(1)(f), (h)). See Court Petitions and Trust Disputes for more on these petitions.
Key Accounting Deadlines
| Step | Timing | NRS |
|---|---|---|
| Earliest written request for list of assets | 60 days or more after trustee’s appointment | 165.030 |
| Trustee serves list of assets | Within 15 days after receiving request | 165.030 |
| Trustee responds to demand for account | Within 14 days after receiving demand | 165.141(2) |
| Trustee provides account after accepting demand | Within 60 days after receiving demand (unless changed by consent or court order) | 165.141(2)(a) |
| Trustee petitions for instructions on a demand | Within 15 days after receiving demand | 165.141(2)(c) |
| Beneficiary petitions to review rejection | Within 60 days after rejection date | 165.143(1) |
| Trustee delivers required account | Within 90 days after end of accounting period (unless otherwise required or extended) | 165.1214(1) |
| Beneficiary delivers written objection to account | Within 90 days after account is provided, or it is deemed approved and final | 165.1214(4)(a) |
| Trustee objects to reviewer’s report (confidential account) | Within 10 days after receiving report | 165.145(6) |
How I Can Help
I help Nevada trustees prepare and deliver accounts, respond to beneficiary demands and requests for asset lists, and seek court instructions when it is unclear who is entitled to an account. I also help beneficiaries make proper written demands and understand their options when a trustee does not respond. Request a consultation to discuss your situation.
This page provides general information about Nevada trust law, based on the Nevada Revised Statutes as of the 2025 legislative session, and is not legal advice. Other Nevada laws, court rules, tax law, and case law also affect trusts. Every situation is different; consult an attorney about yours. Reading this page does not create an attorney-client relationship.
