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Fact sheet

Published 14 May 2026

Am I in scope?

Question: I don’t call myself a tax adviser. Does this still apply to me?

The requirement to register applies to anyone paid to interact with HMRC on behalf of clients’ tax affairs, regardless of job title. This includes but is not limited to — communicating via phone, post or email; sending messages through HMRC’s website or app; sending returns, claims or other documents. If this describes your work, you should use the checker on GOV.UK to see what action you need to take.

Question: I give tax advice voluntarily (such as for a charity), do i need to register?

No. If you are not paid to interact with HMRC on behalf of clients, you do not need to register.

Question: I’m a conveyancer. Do I need to register?

If you are paid to submit Stamp Duty Land Tax (SDLT) returns or otherwise interact with HMRC on behalf of clients, you will be required to register and meet HMRC’s minimum registration conditions. You may already have an SDLT online account, but you should still complete the Tax Adviser Registration process. Registration starts from 18 May, but some businesses will be given longer.

Question: Does paying SDLT to HMRC count as interacting with HMRC for MMTAR purposes?

Yes. Submitting a land transaction return or making a payment to HMRC on behalf of a client both constitute interaction. Outsourcing the filing of a return or payments due does not remove this obligation if your firm remains involved in the interaction.

Question: Why am I required to register as a tax adviser from 18 May, rather than use my Stamp Taxes for Online Agents Service registration?

New rules have been introduced that enable HMRC to monitor and exclude tax advisers from using our services, who are objectively unable to meet HMRC’s Standards for Agents or cannot lawfully act as a tax adviser. The Stamp Taxes for Online Agents Service will still be used to submit SDLT land transaction returns.

Question: Does interacting with HMRC through third-party software or an API count?

Yes. Interactions conducted via third-party software or API connections are treated as interaction with HMRC and bring a firm within scope.

Timing

Question: When do I need to register?

Registration opens on 18 May 2026 and is being introduced in stages. HMRC has published updated guidance on who needs to register and when ahead of the service going live.

Question: How long do I have to register?

Depending on when your business is required to register from, you will have 3 months from your registration date to submit your application. Tax advisers must complete their registration for anti-money laundering supervision (AMLS) before applying for an Agent Services Account (ASA), as HMRC cannot accept ASA applications from tax advisers whose AMLS status is still pending.

Question: Can I continue to interact with HMRC while my registration is being processed?

Yes. During the transitional period, you can continue to interact with HMRC on behalf of clients. SDLT returns will not be blocked if an agent registration number has not yet been entered. However, once your 3 month registration window closes, you will need to be fully registered with HMRC before interacting with us on behalf of any clients. Any future changes to enforcement will be communicated well in advance.

The registration process

Question: Is there a cost to register?

No. Registration is free.

Question: How long does registration take once I’ve submitted my information?

Registration is completed online through a new Agent Services Account application and should take no more than an hour. You’ll be given an estimated timeframe for processing once you submit and we’ll stay in touch throughout to keep you updated.

Question: I already have an Agent Services Account. Do I need to do anything?

If you already have an Agent Services Account (ASA), you do not have to register again. HMRC will be in touch through your account if any additional information is needed, to check you meet HMRC’s new registration conditions. If you have an account for the SDLT online filing system, you will still need to complete the MMTAR registration process.

Relevant Individuals

Question: How do I identify the ‘relevant individuals’ at my firm?

For larger firms, you will need to identify those who manage or organise tax adviser work — with a minimum of 5 individuals required. HMRC will publish further guidance and case studies on this. HMRC has published guidance on which individuals will be subject to checks and will provide guidance with examples on this. If your initial assessment turns out to be incorrect, HMRC’s first response will be to engage with you, not to penalise.

Outsourcing

Question: If I outsource my SDLT returns to a third party, do I still need to register?

In most cases, yes. The requirement applies to the entity that interacts with HMRC. If your firm submits returns or makes payments, you are likely in scope regardless of any outsourcing arrangements. Be cautious of providers suggesting outsourcing removes your registration obligation — HMRC has confirmed this is not generally the case. Check the guidance on GOV.UK to confirm your position.

Safeguards and non-compliance

Question: What if there is an issue with one of my firm’s relevant individuals during registration?

HMRC will not automatically refuse registration due to minor or resolvable issues. Where issues are identified, HMRC’s first response will be to engage with the firm and give them an opportunity to resolve the issue. Firms will have the opportunity to make representations to HMRC and appeal decisions.  

Question: What happens if I miss the deadline?

Unregistered advisers will not be permitted to interact with HMRC on behalf of clients after the deadline, until they have applied for an Agent Services Account  and been accepted. HMRC will always give advisers a reasonable opportunity to comply, but it is important to act in good time. If a tax adviser still attempts to interact with HMRC on behalf of clients after being told to stop, they will be subject to sanctions, including financial penalties and temporary or permanent bans.

Other questions

Question: Does registering as a tax adviser mean I am authorised or qualified to give tax advice?

No. Registration is not a form of regulation and does not reflect your competency or authorise you to advise on tax matters. Your existing professional obligations continue to apply, and you should not take on work outside your competence simply because you are registered with HMRC.