15.04.26

New HMRC rules are coming, will your business be ready?

From May 2026 (only a couple of weeks away), thousands of UK businesses will be required to register with HMRC to continue handling client tax matters.

If your organisation supports clients with tax in any way, even as a small part of your services, you could be affected.

What’s changing?

 Within the recently enacted Finance Act 2026 are new legal requirements for ‘tax advisers’, who interact with HMRC on behalf of clients, to be registered with HMRC and meet certain ‘minimum standards’, this includes any business that:

  • Communicates with HMRC for clients
  • Submits tax forms or returns
  • Provides tax-related advice or documentation

Those who are advising in this capacity must register as a ‘tax adviser’ and meet strict compliance standards.

No registration could result in financial penalties and no interaction with HMRC.

This isn’t just for tax specialists

These rules apply far beyond traditional tax or accounting firms. You may be affected if your businesses works in any of the following types of role or organisation:

  • Professional or legal services
  • Payroll or HR
  • Corporate advisory
  • Property or transaction support
  • Financial services

If you touch client tax matters, you’re likely in scope.

What you’ll need to provide

As part of the registration process, your business will need to submit key information, including:

  • Basic company details (name and address)
  • Confirmation of anti-money laundering supervision
  • Details of ‘relevant individuals’ – typically senior people responsible for managing or overseeing tax-related services within your organisation
  • A formal declaration that your business meets HMRC’s registration conditions

What are “registration conditions”?

In simple terms, HMRC expects both your business and its key individuals to:

  • Be up to date with tax filings and payments
  • Have no significant outstanding tax liabilities
  • Not be subject to anti-avoidance measures
  • Not have serious compliance issues (e.g. tax offences, insolvency, or disqualification)

Important: It’s done per Legal Entity

A crucial point to note is that registration applies at individual legal entity level. So, if your organisation operates through multiple companies or group entities, you’ll need to do the following:

  • Identify which entities carry out tax-related activities
  • Ensure each relevant entity is registered separately

Even if tax work is only a small part of what that entity does, the requirement can still apply.

Key Deadlines

Your timeline depends on your current HMRC setup:

  • No HMRC agent accounts: Register within 3 months from 18 May 2026
  • Existing Self Assessment or Corporation Tax agent account (but no Agent Services Account):
    Register within 3 months from 18 August 2026
  • Payroll providers without other agent accounts:
    Register within 3 months from 18 November 2026

If you already have an Agent Services Account (ASA), you won’t need to re-register but you will need to update your account with additional information.

Many businesses don’t yet have a clear picture of which HMRC accounts they use, this is something you should confirm as soon as possible to avoid missing your deadline.

The risk of doing nothing

Failing to comply could mean:

  • Financial penalties
  • Suspension from dealing with HMRC
  • Disruption to your client services
  • Reputational damage

HMRC can suspend your registration if you breach the registration conditions, or if your conduct falls below required standards (aligned with HMRC’s “Standard for Agents”)

A suspension could directly prevent you from acting for clients on tax matters.

Why acting now matters

  • Deadlines are fast approaching
  • HMRC guidance is still evolving
  • Non-compliance carries both financial and operational risk

Early preparation gives you control and avoids last-minute disruption.

How we can help

If you’d like to stay informed on further developments, or receive future updates on these requirements, please get in touch with our team.

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Author:
Zahra Peacock

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