From Monday 18 May tax advisers will need to register using HMRC’s online registration system for agent services accounts. Tax advisers will have 3 months to register.
In the guidance provided there is an exception for insolvency practitioners, which states that “You will not need to register for an agent services account if you… interact with HMRC on behalf of taxpayers because the law requires it, even if you get paid (for example insolvency practitioners)”.
This exception only applies to insolvency related work post-appointment. Insolvency practitioners who provide tax advice pre-appointment may be required to be named through the registration of their legal entity. Non-insolvency work, such as negotiating a time-to-pay for a client, or speaking to HMRC on behalf of a client regarding a CVA, IVA or Restructuring Plan, would require registration.
Further guidance on this matter is expected, and HMRC have confirmed to R3 that:
- an employee of an insolvency practitioners’ firm who interacts with HMRC on the firm’s behalf (under the authority of the firm) in relation to the insolvency activity, are covered by the exemption for insolvency practitioners
- an external tax advisor, who provides tax advice services to an insolvency practitioner and interacts with HMRC on behalf of the insolvency practitioner, is not covered by the exemption for insolvency practitioners and would be required to register with HMRC
Who needs to register
Anyone who interacts with HMRC about someone else’s tax affairs and gets paid for it is considered a tax adviser, and needs to register for an agent service account. Interaction with HMRC includes:
- phone, post or email
- messages through the GOV.UK website or HMRC app
- sending returns, claims or other documents.
The legal entity that interacts with HMRC must register. Individual employees of the legal entity will not need to register separately. HMRC will carry out checks on relevant individuals within the business. Relevant individuals are people who are responsible for governance, oversight or decision making in relation to tax advice. A relevant individual also incorporates directors, partners and equivalent roles.
You must register even if:
- you do not view yourself as a tax adviser, or describe your work as tax advice
- you work as a sole trader
- helping people with their tax affairs is not your main business
- you only interact with HMRC on behalf of one client
- your business is based outside the UK
Who does not need to register
You will not need to register if you:
- are an employer or in-house tax team, running payroll for your own staff
- only deal with tax affairs for your own company group
- provide tax advice for free (for example charitable services, or helping friends and family with tax)
- interact with HMRC on behalf of tax payers because the law requires it, even if you get paid (for example, insolvency practitioners, some pension or investment firms)
- must interact with HMRC in response to a request for information
- provide payroll, accounting or tax software for others to use, but do not interact with HMRC
When to register by
Tax advisers will need to register from 18 May 2026 and have three-months to do so unless one of the following applies:
- if you already have a Self Assessment or Corporation Tax account, register from 18 August 2026
- if you only provide third-party payroll services on behalf of clients and do not interact with HMRC in any other way, register from 18 November 2026
- if you are financial services organisation, register from 31 December 2026
The online service is available from registration to everyone from 18 May 2026 even if you are not required to do so until a later date.
Conditions to register as a tax adviser
The legal entity, and named individuals, will need to meet certain conditions when they register for an agent services account.
Legal entities
Legal entities will need to provide evidence that they are supervised for anti-money laundering.
In addition, the legal entity must not:
- have any relevant outstanding or unpaid tax (unless covered by a payment plan)
- be subject to a decision by HMRC refusing to deal with you
- be subject to an anti-avoidance sanction or stop notice
- have any relevant, unspent convictions for fraud or tax offenses
- be formally insolvent
- be suspended or permanently banned from registering with HMRC
Relevant individuals
The same conditions apply to relevant individuals as for legal entities (noted above), but they:
- will not need to provide evidence of anti-money laundering supervision
- must not be disqualified from acting as a director, either in the UK or overseas.
There are also requirements for overseas tax advisers