Significant changes to HMRC’s regulatory framework for tax agents are approaching, and conveyancing firms across England and Wales should begin preparing now. From May 2026, firms interacting with HMRC on behalf of clients – including those submitting Stamp Duty Land Tax (SDLT) returns – will fall within a new mandatory tax adviser registration regime.
While much of the early commentary has focused on accountants and tax advisers, it is now clear that conveyancers submitting SDLT returns will also fall within scope of the rules.
For conveyancing firms, the implications go beyond registration itself. Firms should review their internal compliance documentation, training programmes and risk management procedures to ensure they remain aligned with HMRC expectations and relevant quality standards, such as the Conveyancing Quality Scheme (CQS).
Mandatory HMRC Registration for Tax Agents
HMRC is introducing a single registration framework for tax advisers designed to raise professional standards and improve oversight of those interacting with the tax system on behalf of clients.
Registration is expected to begin on 18 May 2026, with a transitional period allowing firms time to comply.
Once the transition period ends, advisers who have not successfully registered could be prohibited from interacting with HMRC on behalf of clients, meaning they would be unable to submit returns or deal with HMRC in relation to client tax matters.
For conveyancing firms, this has a direct impact on their ability to file SDLT returns, which are an integral part of the residential conveyancing process.
Why Conveyancers Are Affected
Government ministers have confirmed during parliamentary discussions that anyone paid to interact with HMRC on behalf of clients must register, explicitly referencing conveyancers submitting SDLT returns.
In practical terms, this reflects HMRC’s view that the preparation and submission of SDLT returns constitutes tax advice or tax agent activity.
As a result, conveyancing firms handling residential property transactions will need to ensure that:
- Their firm meets HMRC’s registration and eligibility requirements
- Relevant individuals within the firm meet HMRC’s “fit and proper” criteria
- Appropriate procedures are in place to support ongoing compliance
The HMRC “Standard for Agents”
Alongside the registration requirement, firms will also need to operate in accordance with HMRC’s Standard for Agents, which sets out expectations regarding professional conduct, competence and integrity.
The standard requires agents to:
- Maintain appropriate technical knowledge and competence
- Ensure tax returns are accurate and based on reliable information
- Keep records of advice provided to clients
- Promote tax compliance and avoid facilitating inaccuracies or evasion
These requirements mean that firms should not only consider technical SDLT training, but also ensure that staff understand the professional responsibilities associated with acting as a tax agent.
Further information can be found here.
Implications for Law Firm Compliance
For many conveyancing firms, the main challenge will not be registration itself, but ensuring that internal governance documents reflect the new regulatory environment.
Policies and procedures that may need reviewing include:
- SDLT policies – to reflect HMRC registration requirements and compliance processes
- Risk management policies – including the operational risk of HMRC de-registration
- Training and development policies – to incorporate tax agent competency expectations
- Client care documentation – clarifying the scope of SDLT advice provided
- Lender compliance procedures – ensuring firms can continue to meet lender panel expectations
For firms accredited under schemes such as the Conveyancing Quality Scheme (CQS), assessors are also likely to expect evidence that these regulatory changes have been properly reflected in the firm’s policies and training programmes.
Preparing Early
Although the registration regime does not formally open until May 2026, early preparation is advisable. HMRC has made clear that the purpose of the reforms is to raise standards across the tax advice market and improve transparency around who is acting for taxpayers.
For conveyancing firms, this means ensuring that both operational procedures and internal governance structures support the firm’s role as a regulated tax agent when submitting SDLT returns.
Firms that take a proactive approach now will be better placed to demonstrate compliance, maintain lender confidence and avoid disruption to their SDLT submission capability.
If you would like assistance reviewing or updating your firm’s SDLT, compliance or risk management policies ahead of the new requirements, feel free to get in touch.
