MTAR10300 - Scope and requirement to register: exceptions to the registration requirement
Overview
There are some activities and roles that are exempted from the mandatory registration requirement, either through statutory exceptions or because they do not meet the definition of providing tax advice by way of business.
This page sets out a list of examples of businesses that are not likely to meet the definition of a tax adviser needing to register with HMRC. It is not exhaustive. Whether a business is required to register with HMRC will depend on the business’s individual circumstances.
It also includes the list of statutory exceptions. In some cases, an individual or business may fall into more than one exception category. Each exception should be considered separately, based on the activity undertaken.
Examples of services that are not in scope of registration
- An in‑house tax professional or team which prepares or files tax returns solely on behalf of their employer and does not provide tax advice or services to external clients.
- An individual who provides tax advice to family members or friends where that advice is not given in the course of their business or professional activities.
- An employee or volunteer of a charity organisation providing free advice and not acting in the course of a business, or anyone else undertaking pro bono work.
- An academic, lecturer or trainer providing general education or training on tax matters without advising on specific client circumstances or acting as an agent, as they do not interact directly with HMRC on a taxpayer’s behalf.
- An insolvency practitioner who is legally required to interact with HMRC on behalf of insolvent individuals and businesses (for example, submitting Corporation Tax returns). In these circumstances, they are acting in a statutory capacity and interacting with HMRC as part of their legal role as office-holder under the Insolvency Act 1986, rather than acting as a tax adviser.
Statutory exceptions
Schedule 20 of the Finance Act 2026 sets out specific statutory exceptions from the requirement to register. Only exceptions set out in legislation have statutory effect. Activities that are not listed in legislation must be assessed against the general registration parameters.
The statutory exceptions apply to businesses that solely do one or more of the following:
- provide tax or accounting software (including payroll software) to a client for use in relation to the client’s tax affairs
- act in relation to customs duty, import VAT or excise matters
- act as VAT representatives for non-established taxable persons
- act as a NI tax representative
- act as a UK representative for vaping duty
- act as Import One Stop Shop (IOSS) intermediaries
- provide tax advice to other entities within the same group as the advising entity
- act in relation to appeals to a court or tribunal
- interact with HMRC where they are required by law to do so (for example, insolvency practitioners or certain regulated financial or pension scheme roles)
- interact with HMRC in response to a request for information from HMRC
Businesses that solely provide non-domestic rating, council tax, or property valuation services will also not be legally required to register.
Mixed activity and edge cases
Where a business provides services that are caught and other services in-scope of the legislation, they will be required to register with HMRC.
A business cannot rely on an exception for part of its activity to avoid registration where other activities meet the legal requirement.
HMRC will continue to work with the sector on more complex scenarios and examples will be added to this guidance.