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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

MTAR30650 - Sanctions and safeguards: temporary relief from suspension

Overview

In certain circumstances, a tax adviser may apply for temporary relief from a suspension of registration pending the outcome of a review or appeal. Temporary relief is a separate statutory process and does not form part of the review or appeal itself. Unless temporary relief is granted, a suspended tax adviser remains unable to interact with HMRC on behalf of clients whilst the review or appeal is being considered. 

Where HMRC approves an application for temporary relief, the tax adviser’s registration will be temporarily reinstated, allowing the adviser to continue interacting with HMRC on behalf of clients, subject to any conditions or restrictions specified in the approval notice. 

Temporary relief is only available where: 

  • HMRC has made a decision to suspend the tax adviser’s registration under section 232 of the Finance Act 2026; and 
  • the tax adviser has either accepted HMRC’s offer to review the suspension decision, or appealed the suspension decision to the First-Tier Tribunal.  

The temporary relief provisions are set out in paragraphs 9 and 10 of Schedule 21 to the Finance Act 2026. 

Circumstances where HMRC must grant temporary relief 

Where an application for temporary relief is related to a decision made solely on the basis that a tax adviser or relevant individual has a relevant amount overdue or a relevant return outstanding, HMRC must approve an application for temporary relief. 

Circumstances where HMRC may grant temporary relief 

Where an application for temporary relief is related to any other reason for suspending a tax adviser’s registration (i.e. not related to a relevant amount overdue or a relevant return outstanding), HMRC must be satisfied that: 

  • the tax adviser has demonstrated that if the application were not approved, they would be unable to continue as a going concern pending the final determination of the review or appeal; 
  • it is appropriate in all the circumstances to approve the application. In determining whether it would be appropriate, the authorised officer must have regard to whether: 
    • there is a prospect of the review or appeal succeeding; 
    • the tax adviser has taken any alternative steps available to protect their position pending the final determination of the review or appeal; 
    • the tax adviser has acted in a timely manner in accepting the offer of the review or in bringing and progressing the appeal. 

Approval of temporary relief 

Where HMRC approves an application, it will issue a notice confirming the approval. 

The notice will: 

  • specify the date from which the approval takes effect; and 
  • where the tax adviser's registration has already been suspended, temporarily reinstate the registration. 

HMRC may approve an application subject to conditions or restrictions specified in the notice. 

Duration of temporary relief 

Where temporary relief has been granted, it will expire: 

  • if the suspension decision is cancelled on review, on the date the suspension decision is cancelled; 
  • if the suspension decision is upheld on review and no appeal is made, on the last day on which an appeal could be made; or 
  • where an appeal is made, on the date the appeal is finally determined.  

Revoking temporary relief  

An authorised officer of HMRC may revoke temporary relief, or vary any conditions or restrictions attached to it, where they are satisfied that a change in circumstances justifies doing so.