Policy paper

HMRC's approach to intermediary harm

Published 14 October 2025

A third party or intermediary can deal with HM Revenue and Customs (HMRC) on behalf of taxpayers. Taxpayers can also get advice and help in meeting their tax obligations from intermediaries. We define an ‘intermediary’ as any individual or business who sits between taxpayers and HMRC. Examples include:

• tax advisers, such as accountants and bookkeepers
• repayment agents, who claim repayments on behalf of their clients
• software providers
• employers (PAYE) and umbrella companies
• contractors for the Construction Industry Scheme (CIS)
• financial organisations and financial advisors
• pension scheme administrators

We recognise that most intermediaries provide value to taxpayers, and support HMRC in administering the tax system. We encourage a high standard of intermediation and work with organisations such as professional bodies and industry leaders to gather feedback on how best to improve HMRC’s service offer to intermediaries.

However, a minority of intermediaries can behave in ways that are harmful to the tax system, HMRC, and taxpayers. Examples of harmful behaviour include, but are not limited to:

• advertising to the public in misleading ways
• using HMRC’s rules and systems in ways that were not intended
• putting in place arrangements that mean taxpayers pay extra interest and penalties on top of the tax they would otherwise owe

Taken together, behaviours such as these can cause harm to the tax system by limiting HMRC’s ability to administer it effectively.  

This document explains what HMRC is doing to deal with harmful intermediary behaviour and what taxpayers should look out for when choosing an intermediary.

What HMRC does

HMRC has different powers it can use to deal with intermediaries that cause harm to the tax system. HMRC has published rules and guidance explaining how intermediaries should act, in tax law or in documents like the Standard for Agents.

When an intermediary causes harm, HMRC looks at each case carefully, and considers whether to act and if so, which powers it should use. For example, we have:

• blocked tax advisers from using HMRC services
• reported harmful behaviour to professional bodies or other enforcement bodies such as the Advertising Standards Authority
• published the names of people promoting tax avoidance schemes
• taken criminal action against intermediaries involved in fraud

Additionally, we can:

• use the data we collect and conduct risk analysis to spot new issues early. HMRC warns the public about new issues by publishing alerts on GOV.UK and sharing them on social media

• work to fix any weaknesses in HMRC’s own systems that intermediaries might take advantage of, for example by changing processes where these are misused by intermediaries

• apply anti-money laundering rules to tax advisers, and if found to be in breach of the rules, advisers are responsible for paying penalties or may be subject to criminal investigation

• review our powers, and how we are using them, to adapt these to patterns of harmful behaviour that change all the time

• work with organisations like the Advertising Standards Authority and the Police to protect the tax system and help taxpayers get fair treatment. In some cases, HMRC may refer you to these organisations to get the help you need

While HMRC takes action against intermediaries where appropriate, taxpayers are still responsible for their own tax affairs, even where they use an intermediary.

What taxpayers should look out for

If an intermediary’s offer sounds too good to be true, it probably is. If an intermediary says they can help you pay less tax, you might end up owing more, plus interest and penalties.

HMRC does not officially approve or endorse any intermediaries. Any intermediaries that say they are ‘HMRC-approved’ are not telling the truth. While HMRC checks that tax advisers follow anti-money laundering rules, it does not check the quality of their services.

Some intermediaries try to look official by copying the GOV.UK website style, using HMRC’s teal colour, or using the government’s crown logo. Intermediaries are not allowed to copy the Government’s official branding.

You should watch out for intermediaries who are not clear in their terms and conditions about their fees or what they are allowed to do on your behalf if you decide to use their services.

Intermediaries should never ask you to sign a blank form or to give them your HMRC login details. You are always responsible for what is on a form that is being submitted on your behalf and should always check any completed documents before signing them, making sure that they are correct and that you are happy for them to be submitted.

Intermediaries will use their account with HMRC to seek taxpayers’ authorisation.

If you want a family member or a friend to help with your tax, they can register with HMRC as a ‘trusted helper’.

Support for taxpayers

HMRC offers advice on how you can appoint a third party to deal with HMRC on their behalf, and how to choose a tax agent.

If you want to use software to manage your tax affairs, you can find software that’s compatible with Making Tax Digital for Income Tax.

There is specific advice for taxpayers that work through umbrella companies.

If you need help, you can contact HMRC to find the right helpline for your situation. You can also report tax fraud and avoidance to HMRC. You can also get help from HMRC if you need extra support.