From May 2026, HMRC will introduce a new online registration regime for businesses that interact with HMRC on behalf of clients. The measures are included in draft regulations contained within the draft Finance Bill 2025-26 and form part of a broader compliance framework designed to strengthen oversight of the tax advice market, improve transparency, and ensure that agents operating in the system meet defined professional and ethical standards.

When registration is required

If your business interacts with HMRC about another person’s or entity’s tax affairs and receives payment for doing so, HMRC will generally regard you as a tax adviser. In such cases, registration will be mandatory and you will need to hold an Agent Services Account (ASA), if you do not already have one.

Interaction is defined widely. It includes communication by phone, post, or email, digital messaging via GOV.UK or HMRC systems, and the submission of returns, claims, or other tax documentation. Importantly, registration is required even where tax is not your primary business activity, where you act for only one client, or where you do not describe your services as tax advice. Sole traders and overseas businesses fall within scope as well.

The legal entity that deals with HMRC must register. Individual employees do not need to register separately, although HMRC will assess certain individuals within the organisation (see below) as part of the approval process.

Who does not need to register

HMRC has clarified that some activities fall outside the regime. Registration is not required where businesses are dealing solely with their own tax affairs, such as employers operating payroll internally or in-house tax teams managing group obligations. Free tax assistance, such as charitable support or informal help to friends and family, is also excluded – this would be relevant to members who use the honorary work exemption to provide some tax assistance without holding an ACCA practising certificate.

Certain statutory or regulated roles are carved out where interaction with HMRC arises from legal obligation rather than agency, eg insolvency practitioners acting in office. Software providers who enable filing but do not interact with HMRC directly are also outside scope.

In addition, some specialist representations such as customs matters, VAT representation, Northern Ireland tax representation, Vaping Duty representation, or tribunal advocacy, do not in themselves trigger registration.

Registration timetable

The new system opens on 18 May 2026. From that date, businesses can begin registering voluntarily, but mandatory registration will be phased:

• Agents without existing Self-Assessment or Corporation Tax agent accounts must register from 18 May 2026.
• Those with existing agent accounts for these taxes must register from 18 August 2026.
• Agents providing only third-party payroll services, with no other HMRC interaction, must register from 18 November 2026.

Once the obligation applies, there is a three-month window to submit the application. During this period, agents may continue acting for clients while HMRC processes the registration.

Failure to register when required will prevent agents from dealing with HMRC. Continued interaction without registration may lead to formal stop notices, bans from registration, and financial penalties.

Registration conditions

To be approved, a business must meet a series of compliance conditions. A central requirement is evidence of supervision under Anti-Money Laundering (AML) regulations.

In addition, the business must not have outstanding tax returns or unpaid tax liabilities (unless covered by an agreed time-to-pay arrangement). It must not be subject to HMRC refusal to deal, anti-avoidance sanctions, stop notices, or bans from registration with HMRC.

Relevant unspent convictions for fraud or tax offences, formal insolvency, or similar compliance failures will also prevent approval.

Relevant individuals

HMRC’s due-diligence process extends beyond the entity itself to certain people within the business, termed “relevant individuals.” These are individuals who play a significant role in directing, managing, or organising the firm’s tax advisory activities.

Who falls into this category depends partly on governance structure and officer numbers. Officers include directors, partners and equivalent roles, including those in overseas entities.

• Where a business has five or fewer officers, all officers are treated as relevant individuals, regardless of their day-to-day involvement in tax work.
• Where there are six or more officers, the business must identify those involved in tax services or oversight.
• If fewer than five individuals meet that description, additional officers must be nominated to bring the total to at least five.

Relevant individuals are subject to broadly the same fitness conditions as the business, although they do not need to evidence AML supervision personally. They must also not be disqualified from acting as a director in the UK or overseas.

HMRC verification process

In most cases, HMRC will verify compliance conditions using information already held within government systems once the online application is submitted. Separate documentation will not usually be required unless HMRC requests further evidence.

However, overseas businesses, or those with relevant individuals based outside the UK, will need to provide authenticated documentation. This must be notarised by an independent qualified notary (or equivalent professional) and, where necessary, accompanied by a certified English translation.

Ongoing monitoring

Registration is not a one-off gateway. HMRC will conduct periodic compliance checks after approval to ensure businesses continue to meet the conditions. Requests for updated information will be issued through the Agent Services Account.

What you need to do

Ahead of the go-live date, affected businesses should review whether they fall within the definition of a tax adviser, confirm their AML supervision status, and identify their relevant individuals. Governance records, tax compliance status, and director eligibility should be validated early to avoid delays once applications open.

Further guidance
Check if and when you need to register as a tax adviser with HMRC

Check if you meet HMRC's conditions to register as a tax adviser