What happens if you interact with HMRC when you are unregistered or suspended as a tax adviser
Find out why your tax adviser registration may get suspended and the sanctions you could get if you interact with HMRC whilst unregistered or suspended.
From 18 May 2026, if you interact with HMRC about someone else’s tax affairs and get paid for it, you may need to register as a tax adviser with HMRC. You, and any relevant individuals, will also need to meet HMRC’s registration conditions.
HMRC may give you a sanction if you interact with us whilst:
- you are unregistered
- your tax adviser registration is suspended
Interacting with HMRC includes contacting HMRC directly and sending returns, claims or other documents.
HMRC will, where possible, support you to comply before applying a suspension or other sanction.
You’ll have a 3-month transition period from the date you need to register. During this time, you will not receive a sanction if you have applied to register but are waiting for HMRC’s decision.
Reasons your tax adviser registration may get suspended
If you are registered to interact with HMRC on behalf of your clients, HMRC may suspend your tax adviser registration if:
- your business or a relevant individual no longer meets HMRC’s registration conditions
- we consider your behaviour to be below HMRC’s standard for agents
If you are suspended, you will not be able to access your agent services account and should not interact with HMRC on behalf of clients.
HMRC’s registration conditions are not being met
HMRC will contact you if your business or any of its relevant individuals no longer meet HMRC’s registration conditions.
You will be given 30 days, from the date of the initial contact, to correct any issues identified. If the issue relates to outstanding or unpaid tax, you will be given 60 days. HMRC will consider any response you send us and may extend the time allowed to correct any issues if appropriate.
If you do not correct the issues within the time specified, HMRC will issue a notice of suspension. The suspension will start 30 days after the date of the notice of suspension.
HMRC will lift the suspension once you have resolved any issues with your registration. You may need to provide evidence to HMRC to show you meet the registration conditions.
Your behaviour is below HMRC’s standards for agents
Tax advisers are expected to comply with HMRC’s standard for agents. If HMRC considers your behaviour to fall below the standard, you may receive a fixed-term suspension.
The suspension will come into effect 30 days after receiving the notice of suspension and will last for up to 12 months.
Sanctions for interacting whilst unregistered or suspended
If you interact with HMRC whilst you are unregistered or your tax adviser registration is suspended, it will be considered a prohibited interaction and your business or any relevant individuals may get sanctions. These include financial penalties and temporary or permanent ineligibility orders (also known as temporary or permanent bans).
| Type of prohibited interaction | The sanction you will receive | What this means |
|---|---|---|
| 1st prohibited interaction | Formal compliance notice | You must stop interacting with HMRC on behalf of clients. This applies until you become registered or your suspension is lifted |
| Each prohibited interaction after the formal compliance notice | £5,000 penalty | If you continue to interact with HMRC after receiving the formal compliance notice, you will be charged £5,000 for each prohibited interaction |
| 5th or any further interaction within a two-year period (starting on the date of the 1st penalty) | £10,000 penalty and a 12-month temporary ban | If you receive 5 penalties within a two-year period (starting on the date of the 1st penalty) the 5th penalty will be £10,000 and you will not be able to interact with HMRC on behalf of clients for 12 months. Any further prohibited interactions in the same two-year period will result in a £10,000 penalty each time |
| Prohibited interaction whilst on a 12-month temporary ban | Permanent ban and £10,000 penalty | If you make a prohibited interaction whilst on a 12-month ban, you will not be able to interact with HMRC on behalf of clients again and will receive a £10,000 penalty for the prohibited interaction and any further interactions |
| Prohibited interaction whilst on a permanent ban | £10,000 penalty | You will receive a £10,000 penalty per prohibited interaction whilst on a permanent ban |
If you receive a temporary or permanent ban, we will notify you and you’ll have 30 days to respond.
Publication of details
If you are issued a financial penalty or a temporary or permanent ban on interacting with HMRC on behalf of clients, we may publish information about you.
This may include:
- your name or the name of your business
- your postcode
- the financial penalty or ban you have been issued
- any other information considered appropriate to make your identity clear
HMRC will let you know in advance about the intention to publish your details and will give you at least 30 days to respond. You will be contacted again to confirm if your information will be published or not.
In most cases HMRC will take down information published about you 12 months after receiving:
- a financial penalty
- a 12-month temporary ban on interacting with HMRC on behalf of clients
If you are issued a permanent ban, the information will not be taken down.
What to do if you receive a sanction or your tax adviser registration is suspended
If your tax adviser registration is suspended or you receive a sanction, you can appeal to the tax tribunal either instead of accepting HMRC’s offer of a statutory review, or after you have received the outcome of a review.
You will not receive a sanction if HMRC, or a tribunal on appeal, considers there to be a reasonable excuse.
Notifying your clients
If your tax adviser registration is suspended for more than 30 days or you receive a temporary or permanent ban not to interact with HMRC, you must take reasonable steps to notify your clients within 30 days.
If you do not, you may get a penalty of £5,000 for each client you should have told.
If you are unable to notify your clients, HMRC may ask you to provide evidence that you tried.