I know nothing about 5227 other than that it has been a highly requested item.  But here are a few things from the Regulation:

1) Electronic filing is required if the TRUST files at least 10 returns (including 941s, 940, W-2s and 1099s).  If the Trust doesn't file that many returns, electronic filing is not required.  Again, I have no experience with it so I don't know if it is common for the Trust to file that many returns or not.

2) For the "hardship", this is what it says "One principal factor in determining hardship will be the amount, if any, by which the cost of filing the return electronically in accordance with this section exceeds the cost of filing the return on paper."

That means if you charge an exorbitant fee to e-file it, it would qualify for the hardship exemption and can be filed on paper.

https://www.law.cornell.edu/cfr/text/26/301.6011-13