MTAR20600 - Checks against registration conditions: business responsibilities concerning relevant individuals
Business-level monitoring and governance expectations
HMRC does not require registered tax adviser businesses to operate in any particular way or to adopt specific governance arrangements solely for the purposes of registration, as long as the business:
- meets HMRC’s registration conditions
- meets HMRC’s standard for agents (GOV.UK)
- correctly identifies and declares the appropriate individuals for checks
HMRC’s approach to monitoring compliance is focused on whether businesses and relevant individuals continue to meet the registration conditions and act in accordance with the HMRC standard for agents.
Where HMRC identifies that relevant individuals may not have been correctly identified, HMRC will work with the business to clarify the position and support them in applying the definition correctly. This will occur before considering whether any further action is needed. Businesses may choose to put in place appropriate arrangements to support ongoing compliance with the registration conditions.
How HMRC will monitor compliance
HMRC’s approach to monitoring compliance is focused on whether businesses and relevant individuals continue to meet the registration conditions and act in accordance with the HMRC standard for agents.
HMRC may carry out further checks where appropriate, including through:
- checks at the point of registration
- targeted re-risking activity, informed by changes in circumstances or risk indicators
- analysis of data across the tax adviser population to identify emerging risks or inconsistencies
- direct engagement with tax advisers where specific issues or concerns are identified
There is no continuous, real‑time reassessment of all registered businesses (or their relevant individuals) by HMRC. However, HMRC will carry out regular checks at appropriate intervals, including on a risk‑based basis, to ensure that registration conditions continue to be met.
Where an issue relates to a relevant individual identified for checks, HMRC may contact the business and, where necessary, the individual, to clarify or resolve any issues. HMRC will handle this in a way that respects the confidentiality of the individual’s personal tax affairs and will not require businesses to have access to, or disclose, detailed personal tax information.
HMRC’s interest is limited to whether the registration conditions continue to be met and does not extend to monitoring internal governance arrangements or management structures.
Communicating obligations within the business
Businesses may find it helpful to take reasonable steps to ensure that those identified as relevant individuals understand why they have been identified and what this means in practice. Knowing that they meet the definition of a relevant individual will help avoid confusion or concern where individuals are contacted as part of the registration process.
Relevant individuals may be contacted by HMRC, where necessary, in connection with registration or compliance checks (for example, to verify information provided by the business or to clarify individual circumstances).
For example, businesses may wish to:
- inform individuals when they have been identified as relevant individuals for registration checks
- share relevant GOV.UK guidance that outlines the expectations of relevant individuals
Overseas businesses and relevant individuals
Overseas tax advisers are not required to provide information on their relevant individuals (whether they are based overseas or in the UK) until HMRC introduces changes to evidence requirements for overseas businesses (see MTAR20700).
Ahead of these changes being introduced, HMRC will contact affected businesses to request details of their relevant individuals and, where necessary, any additional evidence or information to complete checks.
Once the changes to evidence requirements for overseas businesses are in force, all new overseas tax advisers must apply through the new online registration system, rather than the existing overseas registration route.
UK businesses with relevant individuals based overseas
Businesses that do not have an agent services account (ASA) must register online with HMRC (within the appropriate tranche) using the new online registration system and provide these details (including information on any relevant individuals based overseas) as part of the registration process.
Once the changes to evidence requirements are introduced for overseas tax advisers and relevant individuals based abroad, HMRC may request additional information or evidence to complete checks against the registration requirements (see MTAR20700).
Businesses that already hold an ASA will be contacted by HMRC in early 2027 to provide details of any relevant individuals (including those based overseas).
In both scenarios there is no need for businesses to proactively submit evidence to HMRC.