HMRC tax advisor registration standards

Tax advisor registration rules are changing. We explain what they are and who they apply to.

Tax advisors who interact with HMRC on behalf of clients will be legally required to register with the authority and meet new minimum standards, starting from May 2026. There will be a transitional period of at least three months for all tax advisor groups.

The registration process will be digital, with a non-digital alternative available for those who are digitally excluded. This is according to HMRC’s policy paper published on November 26 after Chancellor Rachel Reeves presented the 2025 Budget.

The move follows HMRC’s October 2024 consultation raising standards in the tax advice market: strengthening the regulatory framework and improving registration. The consultation found that stakeholders strongly supported mandatory registration as it could enhance the security of tax advisor services and deter unscrupulous actors.

HMRC said that registration requirements for tax advisors currently vary by service and this is creating administrative burdens and gaps in HMRC’s ability to check whether tax advisors meet minimum standards.

According to HMRC, the policy will improve its ability to monitor and exclude tax advisors who are “objectively unable” to meet HMRC’s Standards for Agents or cannot lawfully act as a tax advisor.

In an email to practitioners, HMRC said it will publish guidance on who needs to register and what they need to do in January 2026, with further details expected on registration timelines and transition arrangements for specific tax advisor groups.

The new requirement for tax advisors to register with HMRC will be legislated for in Finance Bill 2025-26 via primary legislation. Draft legislation for the measure was published in 2025.

Who will be required to register?

According to the draft legislation, the rules will apply to all tax advisors, along with their senior managers, who, in the course of business, assist others with their tax affairs. This includes giving advice, acting as an agent or providing assistance with any document that is likely to be relied on by HMRC. 

The provision will apply irrespective of whether the advisor works for an organisation, is appointed indirectly at the request of someone other than the client and carries out activities other than assisting clients with their tax affairs.  

Unless the tax advisor is registered, they may not interact with HMRC in relation to the tax affairs of a client. This includes: 

• contacting HMRC by telephone, post or email;
• sending a message to HMRC through a website or internet portal;
• filing a return, claim, notice or other document with HMRC (whether electronically or otherwise);
• communicating with HMRC in any other way.

How to apply for registration?

An application to register as a tax advisor with HMRC must contain the name and address of the advisor, the name of each senior manager of the advisor and include a statement as to whether the eligibility conditions have been met. It must also include any other information or evidence that may be specified in a notice published by HMRC.

Applicants who are based in or have ties to countries outside the United Kingdom may be asked to provide different types of information or evidence, as specified in the notice.

What are the eligibility requirements?

To be eligible to register with HMRC and meet the minimum standards, every tax advisor and each senior manager of the advisor must not:

• have any outstanding tax returns or amounts of tax due
• if a time to pay arrangement is being followed, it does not count as an outstanding tax payment
• be subject to a decision by HMRC to refuse to deal with them
• be subject to a sanction or other measure imposed on them by HMRC in relation to tax anti-avoidance activities
• be subject to a suspension or suspension order, or be subject to a prohibition or permanent prohibition order
• be disqualified under Directors Disqualification legislation, or be subject to a similar disqualification in a territory outside the United Kingdom
• be insolvent. 

They must also not have any unspent conviction for various criminal offences including: 

• an offence under section 20BB of the Taxes Management Act 1970 (falsification of documents)
• an offence under the Customs and Excise Management Act 1979
• an offence under section 112 (false representations or obtaining benefit) or 114 (offences relating to contributions) of the Social Security Administration Act 1992
• an offence under the Value Added Tax Act 1994
• an offence under section 35 of the Tax Credits Act 2002 (offence of fraud)
• an offence under the Commissioners for Revenue and Customs Act 2005
• an offence under section 45 or 46 of the Criminal Finances Act 2017 (failure to prevent facilitation of tax evasion offences)
• an offence at common law of cheating the public revenue
• an offence under the law of any part of the United Kingdom consisting of being knowingly concerned in, or in taking steps with a view to, the fraudulent evasion of tax
• aiding and abetting any of the above.

A further condition is that the tax advisor and each senior manager of the advisor meets any standards expected of tax advisors in their dealings with HMRC that are specified in a notice or other document published by HMRC. 

The advisor must be registered with an anti-money laundering supervisory authority or satisfy any alternative requirements HMRC may publish. 

Are there any exceptions to the requirement to register?

However, there are several exceptions from the requirement to register. A tax advisor is not required to register with HMRC in any of the following circumstances: 

• working for an organisation and interacts with HMRC solely in the course of that organisation’s business
• providing payroll, or other tax or accounting, software to a client for use in relation to their tax affairs
• handling matters relating to a duty of customs or a duty of excise or import VAT
• acting as a VAT representative
• handling the tax affairs of a group undertaking
• appealing HMRC decisions to a court or tribunal.

What are the penalties for non-compliance? 

Tax advisors who do not meet the minimum standards or registration conditions will be suspended from interacting with HMRC on behalf of clients until they do meet standards. Sanctions may also apply where tax advisors attempt to circumvent the registration requirements or fail to meet HMRC’s minimum registration standards.  

If a tax advisor fails to register, HMRC will issue a Compliance Notice. If the advisor does not register after receiving this notice, they may face a £5,000 penalty, which could increase to £10,000 for repeated violations. 

A £10,000 penalty will be imposed if tax advisors work while they are suspended or banned from being registered. 

In situations where the breach results from the actions or omissions of a senior manager of the tax advisor, penalties will be imposed on those individuals, who will bear personal liability. 

Where a tax advisor’s registration has been suspended for more than 30 days, the advisor must take reasonable steps to notify each of their clients about the suspension within 30 days from the 31st day of the suspension. Failure to notify clients will result in liability for a penalty of £5,000.

What are the costs of the scheme?

Continuing costs for tax advisor firms will include the requirement to provide annual assurances of HMRC’s minimum registration conditions, including anti-money laundering (AML) supervision status and the certification and translation of documents for overseas tax advisor.

However, HMRC said as the “vast majority” of tax advisors, both UK based and overseas, are already required to hold AML supervision to operate legally, this will not introduce a new burden.

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