Registration will be required for any ‘tax adviser’ who is paid to interact with HMRC in relation to the tax affairs of their clients, regardless of where in the world they and their clients are located.

A tax adviser is defined in the legislation as an organisation or individual who, in the course of a business carried on by them, assists other persons with their tax affairs. 

Assisting with tax affairs is defined within the legislation to include:

• Providing advice in relation to tax
• Acting or purporting to act as an agent on behalf of the other person in relation to tax
• Providing assistance with any document that is likely to be relied on by HMRC to determine the other person’s tax position. 

Interacting with HMRC (as defined in the legislation) includes:

• Contacting HMRC by telephone, post or email
• Sending a message to HMRC through a website or online portal
• Filing returns, claims, notices or other documents with HMRC
• Communicating with HMRC in any other way.

HMRC’s manual MTAR10100 notes that making payments to HMRC is interacting with HMRC for agent registration purposes.  HMRC have confirmed that they are of the view that ‘payment only’ of Stamp Duty Land Tax is interacting with HMRC for agent registration purposes. Please see ‘Does paying SDLT to HMRC count as interacting with HMRC?’ for further information. 

In summary, tax advisers looking to file a return on behalf of their client, or contact HMRC in any way on their behalf will be required to register and will need an Agent Services Account (ASA).

HMRC have confirmed in their factsheet and within their manual MTAR10100 that they are of the view that paying Stamp Duty Land Tax (SDLT) to HMRC counts as interacting for agent registration purposes.  This means that if a tax adviser is paid to submit a SDLT return and / or make a payment to HMRC on behalf of a client, they will be required to register. This means that the outsourcing the filing of a return does not remove the obligation to register if the firm remains involved in the interaction.  HMRC have included guidance within their manuals on conveyancing activities that are in and not in scope. 

Registration is required at firm level.  However, as set out below, certain registration conditions can still apply to individual staff members within the firm and individual officers of the firm (including partners, directors, and LLP members). These individuals are referred to as ‘relevant individuals’. 

Where a tax adviser operates as a sole trader, they will need to register under their own name. When registering, it is important the correct Government Gateway credentials are used to avoid any problems with the registration process.  When registering for the ASA, tax advisers should use agent Government Gateway credentials and when completing the section as a relevant individual, tax advisers should use personal Government Gateway ID credentials. 

We have raised member concerns and queries around whether sub-contractors need to register with HMRC. HMRC are currently drafting detailed guidance on sub-contractors and we have urged for publication as soon as possible before the end of the first registration tranches (18 May to 18 August). When we have further clarity, we will update our FAQs. 

Tax advisers provide tax advice through varying business structures, including some complex legal structures or commercial arrangements. 

MTAR102000 provides that each legal entity must consider its position independently on an entity by entity basis. Each legal entity that meets the definition of ‘tax adviser’ and is paid to interact directly with HMRC on behalf of clients will need to register and apply for an ASA (through the new single streamlined registration process).  One registration in a group or business structure does not cover other legal entities within that group or business structure who also interact directly with HMRC on behalf of clients.    

Members have raised queries with us about the above and over the choice of relevant individuals across complex legal or commercial structures.  We have raised these queries with HMRC and await further clarity. 

HMRC manual MTAR10300 confirms that “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” is not within the scope of agent registration.   HMRC are of the view in-house practitioners do not meet the definition of tax adviser nor are interacting with HMRC on behalf of clients. 

Schedule 20 provides an exemption from registration if the tax adviser is interacting with HMRC in relation to a client who is a group undertaking in relation to the tax adviser. Our understanding is that the intention of this exemption was to provide exemption from registration for in-house tax practitioners who were interacting with HMRC on behalf of other entities within a corporate group structure.    

However, many business structures do not fall neatly into the corporate group definition (meaning given by section 1161(5) of the Companies Act 2006).  We have raised with HMRC the complexities for in-house tax practitioners who work for non-corporate group structures and are providing tax services for other entities within the business structure. 

HMRC are currently considering these complexities and engaging with stakeholders. We will update our FAQs when we have further clarity. 

There are limited exceptions to the requirement to register.

Schedule 20 of the Finance Act 2026 sets out a limited list of exemptions:

• Providers of payroll, tax or accounting software interacting with HMRC in that capacity.
• Tax advisers interacting with HMRC in relation to a client who is a group undertaking in relation to the adviser. (Please see “I work as an in-house tax practitioner, do I need to register?” for more discussion on this exemption.) 
• Where the adviser interacts with HMRC in relation to an appeal to a court or tribunal.
• Where the adviser is interacting with HMRC in response to a request by them.
• Where the adviser is interacting with HMRC on behalf of clients because the law requires them to provide specific information (for example, some pension or investment firms and insolvency practitioners)
• VAT representatives, UK representatives and Northern Ireland (NI) tax representatives.
• Those acting in relation to certain customs duty, and connected excise and import tax matters.  Please note that HMRC published a consultation into the introduction of mandatory registration for customs intermediaries on 23 June 2026. 

Where a tax adviser ONLY interacts with HMRC in relation to one of the exempt areas, they do not need to register. 

HMRC’s manual MTAR10300 now confirms that businesses that solely provide non-domestic rating, council tax or property valuation services will not be required to register. 

HMRC have confirmed that those providing pro-bono tax advice and in-house tax advice to their own business or their employer’s business do not need to register, as they do not fall within the definition of a tax adviser under the legislation. For more detailed information on in-house practitioners please see “I work as an in-house tax practitioner, do I need to register?”. 

Tax advisers without an Agent Services Account (ASA) need to register from 18 May 2026 (with a registration window of three months), unless one of the following applies:

• The tax adviser has an existing Self-Assessment or a Corporation Tax account but no Agent Services Account –  will need to register from 18 August 2026. 
• The tax adviser provides third-party payroll services on behalf of clients and does not interact with HMRC in any other way –  will need to register from 18 November 2026.
• Financial services organisations – will need to register from 31 December 2026.  It is currently expected that a full definition for this group will be published in due course via secondary legislation. 

These tax advisers can still choose to register early from 18 May 2026.

Each registration window lasts three months.  This means each tax adviser has three months from their registration date to submit their application. 

Tax advisers must ensure they have a registration for anti-money laundering supervision (AMLS) in place before applying for an ASA, as HMRC cannot accept ASA applications from tax advisers whose AMLS status is pending.  If you are an overseas agent, please see section ‘What about overseas firms?’

The tax adviser can continue to interact with HMRC on behalf of clients during the three month registration period and whilst HMRC consider your registration (if the tax adviser has submitted their registration application during their appropriate registration window). 

If a tax adviser already has an ASA, they do not need to register again. HMRC will transition existing agents across to the new register.  Please see section  ‘I already have an ASA, how do I transition across?’ 

Registration is via a new dedicated online system, which can be accessed here. 

Please note that the new dedicated online system is not available initially for overseas agents. Overseas agents must apply for an Agent Services Account here. If you are an overseas agent, please see section ‘What about overseas firms? for further information. 

If a tax adviser already has an ASA, they do not need to register again. HMRC will transition existing agents across to the new register.  Please see section ‘I already have an ASA, how do I transition across?’. 

We are aware that, when relevant individuals are trying to complete their own personal sections of the application process, HMRC are seeing applicants using the Government Gateway credentials of their businesses rather than their personal Government Gateway credentials.  HMRC intends to update guidance to make this clearer. In the meantime, HMRC have provided us with the following summary:. 

No – HMRC will not levy charges for initial registration, or to stay on the register.

To register, a tax adviser will need:

• your firm’s Government Gateway user ID and password (you can create these on the sign-in page if you do not have them)
• relevant individuals will need their own personal Government Gateway user ID and password to complete their sections of the registration process (or create them if they do not have them)
• the Unique Taxpayer Reference (UTR) for your tax adviser firm
• the postcode associated with your UTR
• your company registration number (if you have one)
• your VAT registration number (if you have one)
• the name of your anti-money laundering supervisory body and evidence of your supervision *
• the names and contact details of any ‘relevant individuals’ (see below) working for the business registering

*Members supervised by CIOT or ATT can provide their initial registration acceptance email or a screen shot of their entry on our published registers available here and here.

As part of the registration process, the tax adviser will enter the names and contact details of their relevant individuals working for the business registering.  These relevant individuals will also need to complete an online process. This is required so that the relevant individual can confirm their contact details, agree to be a relevant individual and agree to HMRC’s Standard for Agents. 

Through the registration process, the tax adviser will send a link to their relevant individuals, so that they can complete their separate online process.  The tax adviser registering will be able to log in and see if their relevant individuals have completed their individual processes. Once all steps are complete, the tax adviser will be able to submit the application. 

The registration process does enable the tax adviser to complete the process for their relevant individual in certain specific circumstances. 

We’re aware that, when asked to complete information about who you are as relevant individuals within the business, HMRC are seeing applicants using the Government Gateway credentials of their businesses, when they should be using their personal Government Gateway credentials.  HMRC intends to update guidance to make this clearer. In the meantime, here is a quick summary table. 

HMRC will consider the registration application and decide whether or not to approve it. They will then notify you of their decision.   

There is no time limit placed on HMRC to respond to a registration request. 

The tax adviser can continue to interact with HMRC on behalf of clients during their three month registration period and whilst HMRC are processing your registration application (if the tax adviser has submitted their registration application  during their appropriate registration window). 

If the conditions are met, HMRC must approve the registration. 

Where the conditions are not met solely by virtue of the firm or a relevant individual having a tax return or payment outstanding (see below), HMRC may still approve the application if they consider it to be appropriate based on pre-determined thresholds and circumstances. 

HMRC have confirmed in their factsheet that they will not automatically refuse registration due to minor or resolvable issues.  Where minor issues are identified, HMRC’s first response will be to engage with the firm and give them an opportunity to resolve the issue. 

If tax advisers are experiencing technical issues with the registration system, HMRC have advised that they should click on the help options available on the page, for example ‘get help with this page’ or ‘there is a problem with this page’ to report the issues they are facing.  This gives HMRC a time stamp of when the problem occurred, so they can look into the issue further. 

If tax advisers continue to experience issues, please contact HMRC’s online helpdesk or the Agent Dedicated Line (ADL).  If contacting either the helpdesk or the ADL, we recommend that members make clear to the HMRC adviser that their query is in relation to the new agent registration process which went live on 18 May, to help the adviser direct your query. 

If members are having ongoing or significant issues, please do contact [email protected] or [email protected] so we can understand if there are systemic issues which can be raised with HMRC.

Tax advisers who already have an Agent Services Account (ASA) will not need to register but are not exempt from the registration requirements.

Tax advisers who already have an ASA are expected to have a lighter touch ‘transition’, to move their existing account across to the new registration system. 

Tax advisers who already have an ASA will be able to continue to interact with HMRC in the meantime.

It is expected that the transition process will involve the existing tax adviser identifying whom the relevant individuals are within their business and confirming that the business meets the registration conditions.

Technically, the legislation provides that all tax advisers who have an ASA need to meet the requirements from 18 May and HMRC could transition agents across at any time. However, the recent press release published by HMRC indicates that HMRC will contact existing agents via their ASA from 31 December 2026 to 31 March 2027.  At this point HMRC will ask for the further information required to transition existing agents across to the new registration system. The HMRC manual MTAR20200 also confirms that existing agents will be contacted by HMRC in early 2027 to provide details of any relevant individuals. 

We await detailed engagement with HMRC on what transition looks like for existing agents, including the potential timescale of 31 December to 31 March, and will update our FAQs when we have further clarity. 

In the meantime, we recommend existing agents do the following in readiness for transition:

• review your ASA ensuring contact details are up to date, 
• read the legislation and ensure your firm complies and 
• identify your relevant individuals

The relevant individuals are essentially the mind and management, who set the processes and direction for the tax work undertaken by the firm.  However, for some firms the definition may be wider than this in practice as there are minimum numbers of ‘relevant individuals’ who must be named on registration.

Identifying a firm’s relevant individuals is an important decision, as all named relevant individuals have to meet specific registration conditions (see below).

We have fed back concerns to HMRC that the definition of ‘relevant individual’ is very broad in the legislation and may be difficult to interpret. 

HMRC have recently published a manual MTAR20400 which provides some new, additional guidance on how to choose relevant individuals. We welcome comments from members on this new guidance, including any examples that the guidance does not help to address. 

The number of relevant individuals to be named depends on how many ‘officers’ the firm has.  For these purposes, officers include company directors, partners in partnerships, members of LLPs etc (please see below).

It is important to note that the legislation does not cap the number of relevant individuals at five.

Firms with five or fewer officers are required to name:

1. Each officer of the firm; and
2. Every other individual working for them, who plays a significant role;
   1. in making decisions about how the whole or a substantial part of the tax adviser  activities are to be managed or organised; or
   2. the actual managing or organising of the whole or a substantial part of those  activities.

For example, a four partner firm would be expected to name all four partners and any employees who meet the definition of a ‘relevant individual’. If there were two employees who meet the definition, this firm would have six relevant individuals.

Firms with six or more officers are required to name:

1. Each individual (whether officers or employees) who plays a significant role in;  
   1. making decisions about how the whole or a substantial part of the tax advice  activities are to be managed or organised; or
   2. the actual managing or organising of the whole or a substantial part of those activities; and
2. If there are fewer than five officers identified in 1, additional officers to ensure that at least five officers are identified as relevant individuals.

For example, a ten partner firm which includes three tax partners would have to name:

• Each individual who plays a significant role in overseeing the tax work – the three tax partners and any employees, provided they all meet the ‘relevant individual’ definition; and
• At least another two partners of their choice to ensure that there are at least five officers identified. Of course, the firm may choose to name more partners if they wish.
• In this scenario, if there were two employees who met the definition of a ‘relevant individual’, this firm would have seven ‘relevant individuals’ (i.e. the two employees, the three tax partners and two other partners chosen by the firm).

For the purposes of the tax adviser registration, an officer means:

• a company director
• a partner in a partnership
• a member of a body corporate, such as an LLP member
• an officer who responsibilities align with those of a company director and
• any equivalent roles in other types of organisations (such as different kinds of overseas entities)

The conditions are:

1. That the tax adviser and each of the relevant individuals:
   • does not have any outstanding tax returns or payments (unless a time to pay    arrangement has been agreed and not broken),
   • is not subject to a decision by HMRC to refuse to deal with them,
   • is not subject to a relevant anti-avoidance measure,
   • has not, in the last 12 months, had a relevant anti-avoidance penalty imposed on   them,
   • is not subject to a relevant suspension or ineligibility order,
   • is not disqualified as a director in the UK, or overseas,
   • does not have an insolvency practitioner acting in relation to them and
   • does not have an unspent conviction for a relevant offence.
2. The tax adviser is registered for AML supervision or meets such conditions about applying to register for supervision as may be specified in a HMRC notice (no such notice has yet been published).
3. The required number of relevant individuals has been identified (see above).

Once registered, HMRC will monitor ongoing compliance with the registration requirements, and any subsequent failure to meet them may result in an adviser’s registration being suspended.

HMRC also has the power to suspend a tax adviser's registration in certain circumstances, including where their behaviour does not meet expected standards (see question ‘Can HMRC suspend a firm’s registration?’).

We await further clarity on what ongoing compliance will look like for HMRC and tax advisers, including when and how ongoing checks will be carried out. We will update our FAQs once we have further clarity on this. 

If a firm fails to register and attempts to interact with HMRC they can be served with a ‘compliance notice’.  This notice can be treated as withdrawn if the firm subsequently registers.

If a firm attempts to interact with HMRC after a compliance notice has been served (and without it being treated as withdrawn) then HMRC must issue a financial penalty of £5,000. Financial penalties can be issued to the firm or the relevant individual that HMRC deems should be held responsible.

These penalties will increase to £10,000 per contravention if there are repeated attempts to interact with HMRC without being registered. 

Where HMRC financial penalties are issued, HMRC must also issue ineligibility orders.  This ineligibility order is initially temporary (for a period of 12 months), followed by a permanent ineligibility order (a permanent ban) if contravention continues. 

Where conditions are met, HMRC must issue ineligibility orders to the firm or the relevant individual that HMRC deems should be held responsible.  Under s237(1) FA 2026 HMRC may also issue an ineligibility order to a relevant individual where there has been a contravention by the firm. 

Yes.

HMRC will monitor compliance with the registration conditions and, where these are not met, can suspend the firm’s registration.

In addition, HMRC may suspend a firm’s registration for up to 12 months if they consider that the tax adviser has, in the course of interacting with HMRC, behaved in a manner which has fallen below the standards that might be ‘reasonably expected of a tax adviser’ in their interactions with HMRC.  In considering this, HMRC will have regard to any provisions of a “relevant HMRC standard”.  Ministers and HMRC have confirmed that this relevant HMRC standard will be HMRC’s Standard for Agents.   

Before moving to suspend a firm’s registration, HMRC must notify the firm and give them 30 days to either meet the relevant condition or make representations.  This period is extended to 60 days where the breach relates to a late filed return or late tax payment by the tax adviser or a relevant individual.

If a firm attempts to interact with HMRC whilst suspended, they face the same sanctions as set out above for unregistered firms.

The legislation (s232(2) and s232(3) Finance Act 2026) provides that HMRC can suspend a tax adviser’s registration where their behaviour falls below the standard that might be reasonably expected of a tax adviser.  In considering this, HMRC will have regard to any provisions of a “relevant HMRC standard”. 

Ministers and HMRC have confirmed that this relevant HMRC standard will be HMRC’s standard for agents (please see MTAR20200).   HMRC are therefore of the view that this legislation does not change HMRC’s existing powers under the Commissioners for Revenue and Customs Act 2005, nor does it give HMRC any new powers.  HMRC already has the power to refuse to deal with an agent or suspend agent codes. 

During the parliamentary debate on the Finance (No.2) Bill the following assurances were provided by the Exchequer Secretary (HM Treasury) Dan Tomlinson on the use of powers by HMRC: 

• “ HMRC will not review the quality of the advice provided, qualifications or professional conduct. Instead, the measures are specifically about stopping harmful tax advisers who do not meet the basic minimum standards. At registration, tax advisers will be asked to confirm that they will meet HMRC’s standards for agents. The measures do not give HMRC new powers to investigate whether applicants breach the standard for agents, and registration would not be suspended if a minor breach is discovered.”
• “ Clauses 224 to 226 establish registration conditions. 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.”
• “HMRC will suspend a tax adviser only after due process, including offering opportunities to comply and a chance for the adviser to explain whether there is a good reason why they are unable to do so. HMRC will not use these powers for minor breaches.”
• “HMRC will always work with a tax adviser who is genuinely trying to comply, will never suspend a tax adviser when doing so would be unreasonable or disproportionate, and will always consider the nature of any potential breach and how a suspension would impact the tax adviser and their clients.”

These reassurances can be found within the finance bill debate here (from column 223 onwards). 

Ministers and HMRC have confirmed that in considering whether a tax adviser’s behaviour has fallen below the standards expected of them in their interactions with HMRC, HMRC will have regard to HMRC’s standard for agents.     Members are already required to comply with PCRT and we do not expect adherence to HMRC’s standard for agents to place additional burdens on members.

For further guidance on meeting the principles and standards of PCRT when undertaking tax work, members should refer to the current edition of PCRT, effective 1^st January 2026, and available on the ATT and CIOT websites.

Yes.

If a tax adviser disagrees with a decision about their registration, they may: 

• accept an offer of review from HMRC; or
• they may appeal to the tax tribunal. 

A list of appealable decisions can be found in Schedule 21 of the Finance Act 2026 and includes application for registration, suspension of registration, issue of compliance notice, financial penalties, ineligibility orders and decisions regarding an application for temporary relief (see below).

The suspension of a registration will not be automatically put on hold pending the outcome of a review or appeal, but the tax adviser can apply for temporary relief from suspension.   

If the tax adviser has accepted an offer to review a decision on suspension or has appealed to the tribunal, the tax adviser may apply for temporary relief.  Temporary relief may allow the tax adviser to continue interacting with HMRC on behalf of their clients pending the outcome of a review or appeal, but it may be subject to conditions set by HMRC.

The suspension of a registration will not be automatically put on hold pending the outcome of a review or appeal.  The tax adviser must apply for temporary relief.

Where a registration has been suspended due to a late filed return or late tax payment by the tax adviser or a relevant individual, HMRC must approve an application for temporary relief from suspension.

Where a registration is suspended for any other reason, HMRC may approve an application for temporary relief. An authorised HMRC officer may approve an application for temporary relief if the tax adviser demonstrates that they would be unable to continue as a going concern and the officer is satisfied that it is appropriate to approve the application.  The officer will have regard to the prospect of the review or appeal succeeding, alternative steps taken by the adviser to protect their position and whether the tax adviser acted expeditiously in accepting review or bringing an appeal. 

In the run up to registration being introduced, firms should consider:

• Identifying who their relevant individuals are, including considering employees who have a role in managing or making decisions around a substantial part of tax adviser activities
• How many relevant individuals they will be required to identify
• Whether they have existing internal processes to identify that ‘relevant individuals’ have no outstanding tax returns or payments, and whether these processes need to be put in place or updated (as relevant)
• A review of the principles and standards set out in the latest edition of PCRT which all members and students are expected to meet when undertaking tax work. Firms should consider documenting how the firm complies with these principles and with any provision which, if contravened, could cause the firm or a relevant individual to fail a registration condition. Firms should also revise existing procedures where they are unclear
• Checking and documenting that the firm and relevant individuals all meet the registration conditions
• Checking that any directors’ or partners’ agreement permits the removal of someone from their role if they become a relevant individual and fail to meet requirements
• Compiling a list of all online and agent services accounts that your firm uses.
• Reviewing your contact details within your Agent Services Account to ensure they are up to date.
• Ensuring there is a process in place in the event of a situation where HMRC suggests and also does suspend a firm’s registration

One of the conditions of registration is that the tax adviser must be registered for AML supervision or meet such conditions about applying to register for supervision as may be specified in a HMRC notice (see section ‘What are the registration conditions?’). 

As a reminder, if individuals or firms are carrying on a business in the tax and accountancy sector then they must be supervised for anti-money laundering (AML) purposes. If firms are within scope of the AML regulations, and are not registered for AML supervision, this should be brought up to date immediately. 

For members of the CIOT or ATT, the details required to begin the registration process with the CIOT or ATT are set out on the websites, and the webpages also provide information on the AML late registration policy and related guidance. If firms are applying for AML supervision to register as a tax adviser, please also see section ‘When do I need to register?’

Our understanding is that the agent registration process requires an applicant to upload documentation to show AML supervision.  For existing ATT or CIOT supervised firms, we currently anticipate that HMRC will accept a copy of the firm's initial AML registration confirmation email or a screenshot of their entry on the ATT/CIOT’s AML published register available here and here as evidence of AML supervision (see section ‘What information do I need to provide when registering?’) 

If you are an overseas firm please see section ‘What about overseas firms?’. 

Firms based overseas are required to meet the same registration conditions and follow the same registration tranches as UK based agents.   

However overseas firms will need to provide different information or evidence than UK based firms in order to prove that the registration conditions have been met, and will currently need to follow a different registration process 

From 18 May 2026, tax advisers based overseas who are paid to interact with HMRC are required to register. Overseas tax advisers without an Agent Services Account (ASA) will need to register from 18 May 2026, unless one of the following applies:

• The tax adviser has an existing Self-Assessment or a Corporation Tax account but no Agent Services Account – will need to register from 18 August 2026. 
• The tax adviser provides third-party payroll services on behalf of clients and does not interact with HMRC in any other way – will need to register from 18 November 2026.
• Financial services organisations – need to register from 31 December 2026.  It is currently expected that a full definition for this group will be published in due course via secondary legislation. 

Overseas tax advisers have three months to register from the start of their registration window and can continue to interact with HMRC during their registration window and when HMRC are processing their registration application (if the tax adviser has submitted their registration application during their appropriate registration window). 

Overseas tax advisers cannot currently use the new agent registration process, they must continue to use the existing overseas registration route here.  As overseas tax advisers are using the existing registration process for overseas tax advisers, they will not be asked to provide all the information required for the new register, including the details of their relevant individuals. HMRC will need to contact the overseas tax adviser to request this information at a later date. 

Overseas tax advisers who already have an ASA do not need to register again and will be transitioned across to the new register, in the same way as UK based tax advisers will be. Please see ‘I already have an ASA, how do I transition across?’ for further information on transition more generally. 

Overseas tax advisers (regardless of registration tranche) have to provide different information or evidence than UK based firms to prove registration conditions have been met. Our understanding currently is that HMRC do not require overseas agents to send their evidence at this stage (and will begin in early 2027), as they are still to publish the additional evidence requirements.  Whilst we do not know exactly what evidence will need to be provided we do know that evidence will need to be notarised by an independent and qualified notary (or an equivalent professional in the country where the tax adviser is based) and where applicable, have a certified English translation of the relevant document

Firms based overseas and working entirely outside the UK cannot register for AML supervision in the UK, but firms should check and comply with the AML regulations in the country they are based in.   In these cases, the legislation provides that the tax adviser must meet ‘such conditions about applying to register with a supervisory authority for those purposes as may be specified in a notice published by HMRC.’.  HMRC are still to publish such a notice.  We continue to discuss this with HMRC and will update our FAQs, when we get further clarity from HMRC. 

We are aware that overseas agents are experiencing difficulties with the agent registration process, and we are discussing these with HMRC.  We welcome feedback from members on the overseas agent registration process via [email protected] and [email protected]. 

If the tax adviser is a UK tax adviser, please see ‘How do I register?’ for further information on how to register. During the registration process, the tax adviser will be asked to provide details of all relevant individuals, including those based overseas. 

If the tax adviser is an overseas tax adviser, please see ‘What about overseas firms?’ for further information on how to register.  As overseas tax advisers will currently need to use the existing overseas agent registration process, they will not be asked to provide details of their relevant individuals as part of the registration process.  HMRC will need to contact overseas tax advisers separately to request the details of their relevant individuals and additional information. 

There are different evidence requirements for an overseas relevant individual (for both relevant individuals who work for UK and non UK firms) to demonstrate compliance with the registration requirements.  HMRC are still to publish details of these additional evidence requirements. 

It is currently expected that the need for firms to provide evidence on their overseas relevant individuals may begin in early 2027. 

• The legislation is contained in Part 7 and Schedules 20 and 21 of the Finance Act 2026. 
• HMRC has published the following manuals: 
  • MTAR10000 Scope and requirement to register: contents
  • MTAR20000 Checks against registration: contents 
• HMRC has published the following  GOV.UK guidance:
  • Check if and when you need to register as a tax adviser with HMRC
  • Check if you meet HMRC’s conditions to register as a tax adviser
  • What happens if you interact with HMRC when you are unregistered or suspended as a tax adviser 
  • If you disagree with HMRC’s decision about your tax adviser registration
• HMRC fact sheet – Am I in scope? 
• HMRC press release – Tax advisers: check if you need to register under the new rules.
• HMRC interactive checker tool to check if and when you need to register as a tax adviser. 
• The ATT and CIOT hosted a webinar on Mandatory Agent Registration on 20 April 2026, providing an overview of the changes.  A recording of the webinar is available here.
• HMRC are continuing to work on further detailed guidance, which will be published in due course.