Finance Bill 2025-26 briefing: Publication of information about tax advisers

The ATT has produced a Finance Bill 2025-26 briefing on clauses 248 to 250 introduce new powers enabling HMRC to publish information about tax advisers in specified circumstances.

Whilst we support increased transparency around HMRC’s regulatory activity, we are concerned that the proposed publication of postcode information could inadvertently expose individuals to heightened personal safety and security risks, particularly where advisers operate from home addresses. We therefore recommend that the draft legislation be amended to permit publication only of the geographical region of the address of the tax adviser, rather than a postcode.

We are also concerned that the notification requirements in clause 249 lack sufficient certainty. Where HMRC is aware of a material change in circumstances, the legislation currently requires notification “so far as is reasonably practicable”. Given the significant impact of publication on a tax adviser, we recommend that the legislation be amended to require HMRC to notify the adviser within 14 days of becoming aware of a material change in circumstances, and to provide the tax adviser with a meaningful opportunity to make representations before publication or amendment of published information.