Mandatory Tax Advisor Registration
HMRC reminded us in their October Employer Bulletin that the registration for payroll agents to register as tax advisors opens on 18th November 2026. You will have three months after this date in which to register with them.
Their bulletin reads “You do not need to register yet but now is a good time to check whether the requirement applies to you and understand what action you will need to take when your window opens.”
If you miss the registration window HMRC recommends you apply as soon as possible as tax advisors, with registration application references you will still be able to engage with HMRC over the phone while they wait for the application to be processed.
Who is it going to affect?
If you deal with HMRC for someone else’s tax affairs and get paid for it, you may need to register as a tax adviser. HMRC have produced a useful checking tool if you are not sure Check when you need to register with HMRC as a tax adviser
Providing tax services does not have to be the main role of the business but interaction with HMRC on a client’s behalf or acting as an agent for tax affairs does.
Why is it being brought in?
This is a legal requirement brought in for all tax advisors who interact with HMRC on behalf of their clients to ensure they register with HMRC and meet minimum standards. This will improve HMRC’s ability to monitor and exclude tax advisors who are unable to meet the required standards.
Who doesn’t need to register?
- You do not need to register if you are part of an in-house team/group
- Giving advice for free (e.g. through a charity)
- Because the law requires you to, even if you are paid (e.g. insolvency practitioners)
- To respond to a request for information from HMRC
- To develop or provide accounting or tax software (including payroll software)
If I don’t already have an agent service account, how do I register?
If you do not have an agent services account, then you will need to register for one. To do this you need
- Your business/personal Government Gateway ID and password
- UTR for your firm
- Postcode linked to this UTR
- Company registration number (if you have one)
- VAT registration number (if you have one)
- Name of your anti-money laundering supervisory body and proof you are supervised
- Names and contact details of relevant people in your business
HMRC will reject your application for an agent services account if you have applied for anti-money laundering supervision and your application hasn’t yet been approved.
HMRC also state “HMRC will give you the chance to correct any issues or respond before a sanction takes effect. If you are trying to meet the requirement and having difficulty registering, we will work with you to resolve the issue.”
If you don’t have an Agent Services Account start getting your information ready so you can apply when the payroll window opens in November. Do not delay as you only have a three-month transition to register.
You will be able to continue to interact with HMRC during the registration process if you are within their required registration windows.
Sanctions for interacting whilst unregistered include:
- Formal Compliance Notice this is for the first prohibited action (you must stop interacting with HMRC until you become registered or the sanction is lifted)
- £5000 penalty per prohibited interaction after the formal compliance (if you continue to interact after receiving the formal compliance)
- £10,000 penalty and a 12-month ban for the 5th and any further interaction within a two-year period. You will not be able to interact with HMRC on behalf of clients for 12 months.
- Permanent ban and £10,000 penalty if you make a prohibited interaction whilst on a 12-month ban you will not be able to interact with HMRC on behalf of clients again.
- £10,000 penalty per prohibited interaction whilst on a permanent ban.