From 18 May 2026 the HMRC’s digital tax adviser registration system is live. 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. For example, HMRC consider it to include firms who submit Stamp Duty Land Tax (SDLT) calculations on their clients’ behalf. 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.
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.
How do I register?
Registration opens 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 will go live on 18 May.
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 consideration
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.
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.
