HMRC Tax Adviser Registration: How to Check Your Accountant Is Properly Authorised
From 18 May 2026, HMRC began introducing mandatory registration for paid tax advisers who interact with HMRC on behalf of clients. The requirement is contained in the Finance Act 2026 and is being introduced in stages until 31 March 2027.
The new online process replaces several older registration routes. It does not create a public register that lets clients search for every approved accountant. Instead, business owners should ask their adviser to confirm their position and carry out wider checks before authorising them.
Who Must Register?
A business generally needs to register if it is paid to contact HMRC, submit returns or claims, make payments, or send documents for another person. The legal entity providing the service registers, rather than every employee separately.
The rules can cover accountants, tax advisers, payroll bureaux and bookkeepers. For example, a provider of outsourced Xero bookkeeping services may be within scope if it submits VAT returns or otherwise deals with HMRC for paying clients.
Some activities are excluded, including dealing only with an employer’s own payroll, providing free help, developing tax software, responding to an HMRC information request, or representing someone solely in a court or tribunal appeal.
Registration Timetable
| Registration window | Adviser group |
|---|---|
| 18 May to 18 August 2026 | New advisers and advisers without an Agent Services Account, Self Assessment agent account or Corporation Tax agent account |
| 18 August to 18 November 2026 | Advisers with a Self Assessment or Corporation Tax agent account but no Agent Services Account |
| 18 November 2026 to 18 February 2027 | Businesses providing only third-party payroll services and holding no Agent Services Account |
| 31 December 2026 to 31 March 2027 | Financial services organisations |
Advisers have 3 months from the opening of their relevant window to apply. They may continue dealing with HMRC during that period and while HMRC considers an application submitted on time.
Need Expert Accounting Advice?
If you are unsure about tax, bookkeeping, payroll, property accounts or business finances, speak to the team at FHP Accounting for clear, practical guidance.
Businesses that already hold an Agent Services Account do not submit a fresh registration application. HMRC may contact them through the account to check that the business and its relevant individuals meet the new conditions.
What Conditions Apply?
An applicant must normally demonstrate appropriate anti-money laundering supervision. The business and relevant individuals must also satisfy conditions concerning tax compliance, insolvency, fraud or tax convictions, director disqualification and previous HMRC sanctions.
Professional-body membership remains useful but is separate from HMRC registration. Membership of ICAEW, ACCA, CIOT or ATT may indicate qualifications, continuing professional development and access to a complaints process, but it does not by itself prove that the adviser has met HMRC’s registration requirement.
How to Check Your Accountant
HMRC provides an online checker showing when an adviser needs to register. It is designed to determine the adviser’s obligations, rather than to act as a searchable public directory for clients.
Ask your accountant:
- Does your firm have an Agent Services Account?
- Which registration window applies to you?
- Have you applied, or were you already registered before 18 May 2026?
- Who supervises the firm for anti-money laundering purposes?
- Do you belong to a recognised professional body?
- Do you hold professional indemnity insurance?
You should also confirm that the firm is separately authorised to act for you. Even when an agent prepares and submits a return, you remain responsible for the information it contains.
These checks matter particularly where you use a property tax accountant or an outsourced finance function with access to sensitive financial records.
What Happens If an Adviser Does Not Register?
The first prohibited interaction after the transition period can lead to a formal compliance notice. Each further interaction after that notice may attract a £5,000 penalty. A fifth penalised interaction within 2 years can result in a £10,000 penalty and a 12-month ban. Continued interaction during a temporary ban can lead to a permanent ban.
An adviser suspended for more than 30 days, or given a temporary or permanent ban, must take reasonable steps to notify affected clients within 30 days. Failure can result in a £5,000 penalty for each client who should have been told.
For related guidance, read about Making Tax Digital and quarterly update returns, RTI reporting changes and what documents you need for your tax return.
Work With a Firm That Has It Covered
FHP Accounting supports businesses, landlords and property managers across Nottingham and the East Midlands. To discuss your accounting and tax requirements, get in touch with our team or book a free consultation.
I lead FHP Accounting, an accountancy practice specialising in Commercial and Residential Property Accounting. Our goal is to make the administration of running property portfolios easier for landlords, managers, and investors — allowing you to focus on what you do best, while we take care of everything behind the scenes.
Need Expert Accounting Advice?
If you are unsure about tax, bookkeeping, payroll, property accounts or business finances, speak to the team at FHP Accounting for clear, practical guidance.
