New requirement for tax advisers to legally register with HMRC

 

Requirement for tax advisers to register with HMRC and meet minimum standards

From 1st April 2026, tax advisers across all areas of tax, including R&D tax claims, who interact with HMRC on behalf of clients, will be legally required to register with HMRC and meet minimum standards for agents. This new HMRC requirement aims to improve service quality by reducing errors, deterring unscrupulous actors, reducing fraud, and enhancing HMRC’s oversight. The R&D tax adviser registration rules are part of a wider initiative to improve compliance and transparency in the tax advisory industry and are being introduced through the Draft Finance Bill under the new heading: “Tax Advisers Registration.”

Read the full Gov.uk update

What is the policy aiming to achieve?

The objective is to ensure that anyone dealing with HMRC on behalf of taxpayers is properly qualified, compliant, and accountable. Specifically, the policy is designed to:

• Raise overall standards in tax advice
• Reduce non-compliance and tax-related abuse
• Improve HMRC’s ability to monitor, suspend, or exclude unfit advisers
• Bring consistency across HMRC’s various services and registration systems

HMRC will assess advisers against its Standards for Agents, as well as principles from the Professional Conduct in Relation to Tax (PCRT) and the Tax Agents Handbook.

Under the new framework, tax advisers must meet several compliance and conduct criteria to register and maintain their status.

Meeting HMRC’s Standards for Agents

To be eligible, tax advisers must:

• Have no outstanding tax returns or unpaid liabilities
• Not be under HMRC sanctions, suspension, or prohibitions
• Not be disqualified directors, insolvent, or hold unspent convictions for tax-related offences
• Be registered with an Anti-Money Laundering (AML) supervisory body

Following the principles of PCRT

Tax advisers will be expected to:

• Promote tax compliance
• Provide accurate and complete advice
• Maintain competence through regular continuing professional development (CPD)
• Keep client data secure and confidential
• Avoid conflicts of interest and disclose them when they arise
• Cooperate fully with HMRC investigations

Complying with HMRC’s Tax Agents Handbook

Tax advisers must also:

• Ensure all HMRC documentation is correct and complete
• Demonstrate that both they and their clients have taken reasonable care
• Use HMRC systems properly and stay updated on relevant changes
• Follow guidance on tax repayment assignments, especially after the post-March 2023 changes

Mandatory registration will come into force on 1 April 2026. HMRC will allow for a minimum three-month transition period to help advisers comply with the new rules.

To support this rollout, HMRC is investing £36 million in modernising its registration and compliance systems. Once registered, advisers will need to submit an annual declaration confirming they continue to meet all compliance and conduct standards.

Failure to comply could result in suspension or other sanctions, including being prevented from acting on behalf of clients.

Who is affected by the changes?

Tax advisers

Advisers who act on behalf of clients will need to be registered and compliant by April 2026. Those who are not registered or fail to meet the standards will risk removal from the system and possible penalties. This includes those specialising in R&D claims, as the new R&D tax adviser registration requirements apply to all agents interacting with HMRC

Businesses

Organisations that work with tax advisers may face some administrative costs in the short term. However, they should benefit from more reliable, regulated advice and improved service from their agents.

Continuing costs for tax adviser firms will include the requirement to provide annual assurance of things such as anti-money laundering (AML) supervision status and the certification and translation of documents. However, the vast majority of tax advisers, both UK based and overseas, are already required to hold AML supervision to operate legally, so this will not introduce a new burden.

Taxpayers

Most individual taxpayers will not be directly affected. The impact would arise only if their adviser fails to meet the new requirements and is suspended or removed from HMRC’s systems.

In summary

The introduction of mandatory registration and minimum standards for tax advisers, including those involved in R&D tax relief claims, marks a significant shift in HMRC’s approach to improving tax compliance and service quality. From April 2026, only registered and compliant tax agents will be permitted to interact with HMRC on behalf of clients, reinforcing accountability and professionalism across the industry.

For businesses claiming R&D tax credits, this new framework provides greater assurance that advisers are qualified, ethical, and operating within HMRC’s compliance guidelines. It will also help reduce the risk of fraudulent R&D tax claims, which have been a growing concern in recent years.

Now is the time for tax agents and R&D consultants to review their internal processes, ensure alignment with HMRC’s Standards for Agents, and confirm their ongoing registration with a recognised Anti-Money Laundering (AML) supervisory body. Proactively adapting to these changes will not only ensure continued eligibility to act on behalf of clients but also strengthen trust in the R&D tax sector overall.

Staying ahead of the R&D tax adviser registration rules will be crucial for compliance and business continuity in 2026 and beyond. Businesses seeking to make R&D tax claims should take care to partner with advisers who are fully registered and compliant under the new rules, helping to safeguard the integrity and success of their R&D tax credit claims.

If you would like to speak to us regarding your R&D tax journey and where we can support your business, book a free 1-2-1 consultation today or get in touch with us via the form below.