HMRC recently published new guidance on mandatory registration for tax advisers, coming into force in May 2026, but there is still uncertainty surrounding the new regime, with some professional bodies asking for further clarification from HMRC.
Following the October 2024 consultation 'Raising standards in the tax advice market: strengthening the regulatory framework and improving registration', the government concluded that from May 2026, it will be compulsory for all tax advisers (who interact with HMRC on behalf of a client) to register with HMRC and meet minimum standards.
A tax adviser interacts with HMRC if they:
- Contact HMRC by phone, post or email.
- Send a message to HMRC through a website or internet portal.
- File a return, claim, notice or other document with HMRC (whether electronically or otherwise).
- Communicate with HMRC in any other way.
Eligibility conditions apply to register; if these are not met, HMRC may reject an application. HMRC will continuously monitor conditions to ensure the adviser is meeting the standards.
To apply for mandatory adviser registration, an Agent Services Account (ASA) will be needed.
- HMRC have advised that from 18 May 2026, they will introduce a new online registration system for ASAs.
- For advisers who meet the conditions for mandatory registration but do not currently hold an ASA, they will be required to apply for one.
- Registration will take place in stages.
- Exactly when an adviser has to register will depend on their circumstances.
HMRC have confirmed that agents who already have an ASA will still need to register, but the process is expected to be 'lighter' and involve a transition to move their existing account across to the new registration platform.
- HMRC will contact these agents through their ASA.
- Agents should therefore check that contact details in their ASA are up-to-date.
The Institute of Chartered Accountants in England and Wales (ICAEW) has advised that the new guidance should be treated with caution, stating that it oversimplifies the legislation and leaves some questions unanswered. Specifically, it has raised concerns around the following:
- The guidance does not explain when agents require an ASA. The ICAEW assumes all agents will have to apply for an ASA even if they are applying for a service that does not currently need one. This is not clear from the guidance.
- The guidance inaccurately describes who is a 'relevant individual'.
- The guidance lacks detail in some areas, for example, how to determine an 'officer' of the business for the purpose of agent registration.
- The guidance does not provide the clarity that tax advisors are seeking, for example, on whether family offices need to register and if registration is at an entity or a group level.
The Association of Taxation Technicians (ATT) has raised concerns about the broad definition of 'relevant individual', pointing out that the definition may be difficult to interpret.
Additionally, the ATT has raised concerns with HMRC over the requirement for more clarity and guidance surrounding the expected standards advisers need to meet to maintain their registration.
Both professional bodies have said they will continue to work with HMRC and update on further developments.
Useful guides on this topic
Mandatory tax adviser registration with HMRC
From May 2026, all tax advisers who interact with HMRC on behalf of clients will be required to register with them. Who will be required to register? What conditions must be met? What are the consequences of non-compliance with 'mandatory tax adviser registration'?
HMRC's Customer Charter
This is a freeview 'At a glance' guide to HMRC's Customer Charter. HMRC's Charter sets out what taxpayers can expect from HMRC and what HMRC expect from taxpayers. The latest version was issued in November 2020.
Professional Conduct in Relation to Taxation
The Professional Conduct in Relation to Taxation (PCRT) sets out the ethical and professional standards expected of members of the seven authoring professional bodies when advising on UK tax matters.
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