Requirement for tax advisers to register with HMRC and meet minimum standards
Published 21 July 2025
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Who is likely to be affected
The measure will affect tax advisers who interact with HMRC on behalf of their clients. Tax advisers are those who provide professional tax advice and services.
General description of the measure
The measure introduces a legal requirement for tax advisers who interact with HMRC on behalf of their clients to register with HMRC and meet minimum standards.
Policy objective
The policy ensures all tax advisers interacting with HMRC on behalf of their clients meet minimum standards. The changes will improve HMRC’s ability to monitor and exclude tax advisers who are objectively unable to meet HMRC’s Standards for Agents or cannot lawfully act as a tax adviser.
Background to the measure
Currently, registration requirements for tax advisers vary by service, creating administrative burdens and gaps in HMRC’s ability to check whether tax advisers meet minimum standards.
Following the October 2024 consultation Raising standards in the tax advice market: strengthening the regulatory framework and improving registration, stakeholders strongly supported mandatory registration, stating that it could enhance the security of tax adviser services and deter unscrupulous actors.
The government will mandate registration from 1 April 2026 and is investing £36 million to modernise existing registration services.
Detailed proposal
Operative date
Mandatory registration starts 1 April 2026, with at least a three-month transition period. Details will be communicated in advance to stakeholders.
Current law
Not applicable.
Proposed revisions
Not applicable.
Summary of impacts
Exchequer impact (£ million)
| 2024 to 2025 | 2025 to 2026 | 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 |
|---|---|---|---|---|---|
| Nil | Nil | £5 | £35 | £40 | £40 |
These figures are set out in table 5.1 of Autumn Budget 2024 and have been certified by the Office for Budget Responsibility. More details can be found in the policy costings document published alongside Autumn Budget 2024.
Economic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
Individual taxpayers will not be directly affected by the requirement for their tax advisers, whether UK based or overseas, to register with HMRC before they can act on their behalf.
However, individual taxpayers may be affected if their tax advisers are no longer able to act on their behalf because they are either unable to satisfy the new registration requirements imposed on (UK based and overseas) tax advisers, or if their tax adviser is subject to sanction. Mandatory registration will be implemented from 1 April 2026 and communications and guidance will be issued to tax advisers so they are aware of the changes and can take the appropriate steps to comply with any new requirements. Where a tax adviser fails to meet HMRC’s minimum standards, their clients have the choice of engaging the services of other registered tax advisers.
This measure is expected overall to have no impact on individuals’ experience of dealing with HMRC. It is not expected to impact on family formation, stability or breakdown.
Equalities impacts
Most tax advisers who will need to register with HMRC as a result of this policy are businesses and will be able to register using a digital process. A non-digital alternative will be available for the small number who are digitally excluded.
Overseas tax advisers will be required to provide additional evidence when registering and will as a result incur additional costs.
Individuals may be impacted by the measure if their tax adviser can no longer act on their behalf or is suspended.
HMRC does not hold protected characteristic data on tax advisers who are individuals, or on individuals who use tax advisers, and so the impacts to those groups cannot be conclusively determined.
Impact on business including civil society organisations
This measure will have a negligible impact on tax adviser firms who engage with HMRC by way of business. These tax adviser firms will be bound by the new requirement to register if they choose to interact with HMRC on behalf of their clients.
One-off costs for those businesses could include familiarisation with these changes, as well as costs associated with registering with HMRC.
The requirement for overseas tax advisers to provide additional evidence (translated into English where necessary), will impose additional costs. It is not envisaged the certification and translation of documents will be unduly costly.
Following implementation of the IT solution, one-off savings may be realised by those tax adviser firms as they will now register through a single registration route and will be able to do this digitally. This is because current registration processes vary across different HMRC services and often require initial postal applications.
Continuing costs for tax adviser firms will include the requirement to provide annual assurance of things such as anti-money laundering (AML) supervision status and the certification and translation of documents. The vast majority of tax advisers, both UK based and overseas, are already required to hold AML supervision to operate legally, so this will not introduce a new burden.
The experience of a business’ customers is expected to remain the same as the new requirements will not greatly change how businesses interact with HMRC.
Tax advisers who do not meet the minimum standards or registration conditions will be suspended from interacting with HMRC on behalf of clients until they meet the minimum standards. Sanctions may also apply where tax advisers attempt to circumvent the registration requirements or fail to meet HMRC’s minimum registration standards.
This measure is not expected to impact on civil society organisations.
Operational impact (£ million) (HMRC or other)
To improve the tax adviser registration process HMRC will make changes to its IT systems and supporting processes. As announced at Autumn Budget 2024, the government is investing £36 million to improve HMRC’s registration processes.
Other impacts
Other impacts have been considered and none have been identified.
Monitoring and evaluation
The measure will be kept under review through communication and engagement with affected tax adviser groups.
Further advice
If you have any questions about this change, please contact Benjamin Jones on 03000 528 758 or email benjamin.jones@hmrc.gov.uk.