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HMRC internal manual

Mandatory Tax Adviser Registration

From:
HM Revenue & Customs
Published:
1 June 2026
Updated:
14 August 2026 - See all updates

MTAR30200 - Sanctions and safeguards: suspensions

Overview

Suspensions act as the primary sanction available under the tax adviser registration regime. This provision is set out at section 232 of the Finance Act 2026.  

A suspension prevents a tax adviser from interacting with HMRC on behalf of clients in relation to activities that are within scope of the registration requirement. This means that the tax adviser cannot submit tax returns, make claims, respond to compliance checks, submit disclosures or contact HMRC in any way (including via phone, webchat, email or correspondence) on behalf of their clients. In practice, a suspension also results in the tax adviser losing access to their agent services account (ASA).  

A suspension under the tax adviser registration regime applies to all in-scope interactions with HMRC on behalf of clients, regardless of the channel through which those interactions take place. This means that a tax adviser cannot avoid the effect of a suspension by interacting with HMRC through a route that is not connected to their ASA. However, a suspension does not prevent interactions that fall outside the scope of the registration requirement, nor does it affect a tax adviser’s ability to interact with HMRC as a taxpayer.   

For more information about interactions that are not in scope of the registration requirement, refer to MTAR10300. 

There are two types of suspension: 

  • a suspension for failing to meet one or more registration conditions 
  • a suspension for failing to meet HMRC’s standard for agents (up to 12 months)  

HMRC may take reasonable steps to ensure that the tax adviser continues to meet the registration conditions at the end of a suspension period.  

Suspension for failing to meet one or more registration conditions 

HMRC may suspend a tax adviser where: 

  • the tax adviser is registered with HMRC; and  
  • HMRC identifies that the tax adviser or a relevant individual no longer meets one or more registration conditions and the failure is not or cannot be rectified. 

Once the suspension is in place, the tax adviser will be unable to access their ASA or interact with HMRC through any other channel on behalf of clients in relation to activities within scope of the registration requirement. For more information about activities that are in scope of the registration requirement, refer to MTAR10100. 

This type of suspension continues until the tax adviser is able to satisfy HMRC that the relevant registration condition(s) have been met. Once HMRC is satisfied that they are compliant with the conditions, the suspension will be lifted and a notification will be sent to the tax adviser. The tax adviser may then resume interactions with HMRC on behalf of clients. 

Suspension for failing to meet HMRC’s standard for agents 

HMRC may impose a suspension where a tax adviser behaves in a way that falls below the standards that might reasonably be expected of a tax adviser in their dealings with HMRC. For more information see the standard for agents published on GOV.UK. 

HMRC's approach to breaches of the standard for agents was outlined by ministers during the Finance (No. 2) Bill (Sixth sitting):  

At registration, tax advisers will be asked to confirm they understand and will meet HMRC’s standards for agents. Currently, if HMRC concludes that an adviser has significantly breached the standards for agents, it can refuse to interact with that adviser. In line with that, as a result of these clauses, a serious breach would result in the adviser’s registration being suspended—that is not the case for a minor breach.

Further information can be found in column 225 of the Hansard record of the Finance (No. 2) Bill Committee proceedings.  

A suspension for failing to meet HMRC’s standard for agents may be imposed for a period of up to 12 months.  

At the end of the suspension period, HMRC will lift the suspension in accordance with the legislation. A suspension for failing to meet HMRC’s standard for agents cannot be extended, and HMRC cannot convert this type of suspension into a suspension for failing a registration condition without beginning a new sanctions process and applying the relevant statutory safeguards. 

Opportunities to rectify issues and make representations  

Before a suspension can take effect, HMRC must notify the tax adviser of its decision and grant a statutory period during which the adviser may make representations or, where applicable, rectify the underlying issue.  

In most cases, this statutory period is 30 days, starting from the date that the suspension notice is issued. This period is extended to 60 days where the failed registration condition relates to a relevant amount overdue or a relevant return outstanding, as set out in section 227(2)(a) of the Finance Act 2026.  

During the applicable 30- or 60-day period, the tax adviser may: 

  • take action to satisfy the relevant registration condition; and/or 
  • make representations to HMRC regarding the proposed suspension. 

HMRC may, by notice to the tax adviser, extend the period for making representations.  

HMRC will aim to engage with the tax adviser where possible before issuing a suspension notice and provide an opportunity to resolve issues voluntarily. This pre-notification engagement would be in addition to the statutory periods provided by the legislation.