HMRC To Require Mandatory Registration For Tax Advisers

From May 2026, individuals and businesses acting on behalf of clients in matters involving HM Revenue & Customs (HMRC) will be obligated to register with the department. This measure, announced following a government consultation in 2024, forms part of broader efforts to enhance standards within the tax advice sector.

Initial guidance published by HMRC details which advisers must register, the timeline for rollout, and the standards expected of those interacting with HMRC on clients’ behalf.

Introduction of Mandatory Registration

HMRC's new requirement stipulates that all tax practitioners representing clients before the department must complete a registration process beginning in May 2026.

The provision forms part of the current Finance Bill, reflecting the government’s intention to improve oversight and accountability among tax advisers.

The initiative follows an extensive consultation period, after which the government resolved to proceed with a system that applies to most paid agents and advisers engaging with HMRC on any aspect of a client’s tax affairs.

Details of the Registration Process

Initial guidance from HMRC provides clarity on who must register and outlines a proposed registration procedure aimed at being straightforward and accessible.

The government has announced plans for supporting investment to ensure the new system is easy to use for advisers and businesses of all sizes.

Registration will apply to the legal entity dealing with HMRC, such as a company, partnership, or registered sole trader. Individual employees will not be required to register separately, but HMRC will perform checks on certain individuals within the registered organisation.

Scope of the Registration Requirement

According to guidance and statements from professional bodies, any business or practitioner paid to interact with HMRC regarding another person’s or entity’s tax matters must complete the registration process.

Activities in scope include correspondence by telephone, post, email, the GOV.UK website, or HMRC’s app, as well as filing tax returns, claims, and other documents on behalf of clients.

This requirement will extend to businesses with a single client and those based overseas that provide such services. Registration is required regardless of whether the business markets itself as a tax adviser.

Exemptions and Specific Cases

A range of specific exemptions to the new requirement has been outlined. Businesses conducting in-house payroll services, intra-group tax matters, or offering free-of-charge tax advice will not be required to register.

Further exclusions apply in instances where the business only interacts with HMRC for customs or import VAT, acts solely as a VAT representative,

Northern Ireland tax representative, or as a representative for Vaping Duty. Additionally, representation of clients exclusively in court or tribunal proceedings is exempted.

Professional Reactions and Guidance

Professional bodies, including the Institute of Chartered Accountants of Scotland (ICAS), are participating in ongoing discussions with HMRC regarding the implementation of the new regime.

ICAS has encouraged its members to submit questions or feedback on the registration framework, reflecting the profession’s engagement in shaping practical guidance and compliance measures.

The government asserts that these changes will contribute to raising standards across the tax advice market, strengthening consumer protection and promoting transparency.