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News

Do you need to register as a tax adviser?

11 June 2026

HMRC's digital tax adviser registration system went live on 18 May 2026. This means firms need to provide evidence to HMRC that they are supervised for anti-money laundering.

The Finance Act 2026 introduced the new obligation for some solicitors including most residential conveyancers. Under Part 7, all of those who 'interact' with HMRC as part of a service for others must register as a tax adviser.

HMRC's guidance outlines that: 'If you interact with HMRC about someone else's tax affairs and get paid for it, HMRC considers you to be a tax adviser.'

Interacting with HMRC includes: 

  • phone, post or email 
  • messages through the GOV.UK website or HMRC app 
  • sending returns, claims or other documents. 

Who does this apply to?

This is not limited to firms who file tax returns or other documents with HMRC on behalf of their clients.

You will not, though, need to register with HMRC if you only interact with them to represent a client in appeals to a court or tribunal. 

If you already have an Agent Services Account with HMRC, no action is required. HMRC will be in touch over the coming months to make the necessary arrangements. 

HMRC has now published further detail on which firms will need to register. Among other things, HMRC confirms that this includes:

  • conveyancers who:
    • submit Stamp Duty Land Tax returns to HMRC on behalf of clients 
    • interact with HMRC about a client’s SDLT liabilities 
    • make payments of SDLT or any other taxes arising from property transactions on behalf of clients
    • otherwise interact with HMRC on behalf of clients in relation to SDLT or any other taxes arising from property transactions.
  • practices which might outsource these or similar services, in which case both the conveyancing firm and the outsourced provider would have to register.

You are also likely to need to register if you manage a client's tax affairs, for example as an executor or under a deputyship.

How do I register?

Registration opened on 18 May 2026. Firms, sole practices, or freelance solicitors who are under AML supervision are eligible. 

To register, you will need to apply for an agent services account (ASA) – this is required even if you have an account for the SDLT online filing system. The system went live on 18 May, and  you can register here.

You will need to upload proof of your firm's status. For solicitors we regulate, this means a pdf copy of the entry for your firm, sole practice, or freelance practice on the Solicitors Register. This must show the relevant SRA number and office address.

To read more about the process, see HMRC's Guidance.

Other considerations

Note that HMRC's definition of a tax adviser is different to that in regulation 11(d) of the MLR 2017. This is a separate requirement and notifying us that you are a tax adviser for the purposes of the MLR 2017 will not mean you are a tax adviser for HMRC's purposes.

By way of example: HMRC’s guidance notes that providing advice (for example, explaining the tax consequences of a property transaction to a client) without interacting with HMRC on the client’s behalf would not fall within their definition of a tax adviser. It would, however, fall squarely within the definition at regulation 11(d).  

There will be a three-month transition period. From 18 August 2026, HMRC will not accept communications on a client's behalf from anyone not registered as a tax adviser.

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