Finance Bill 2025-26 briefing: Tax adviser registration with HMRC

The ATT has produced a Finance Bill 2025-26 briefing on clauses 220 – 246, and Schedules 19-20 which introduces a new requirement for all tax advisers to register with HMRC if they wish to interact with them on behalf of a client, unless a limited exception applies.

Whilst we appreciate the importance of HMRC having improved visibility of tax advisers operating within the system, we are concerned at the speed with which this measure is being introduced. Despite the changes coming into effect in a matter of months, we do not yet know exactly how or when advisers will be required to register. We would therefore recommend that introduction of mandatory registration is delayed until April 2027 at the earliest. If not, HMRC needs to issue further clarification urgently.

We are also concerned that, as registration will only be required of tax advisers who directly interact with HMRC, the more unscrupulous actors in the market could circumvent these new rules. Care needs to be taken that this legislation does not merely impose additional compliance requirements on compliant tax advisers.

Despite the publication of this legislation, there remain a number of areas of uncertainty regarding exactly which individuals within tax adviser firms will need to be named as part of the registration process. Further guidance is urgently needed.

Finally, we note that the legislation allows for a tax adviser’s registration to be suspended where certain standards of behaviour are not met. However, the required standards of behaviour are not set out in the legislation, and are instead relegated to a future notice to be published by HMRC. Given the potentially severe consequences of a tax adviser’s registration being suspended, we would have strongly preferred that the applicable standards be identified directly in the primary legislation.