Tax adviser registration: what do you need to know?
On 18 May 2026, it became mandatory for tax advisers to register with HM Revenue & Customs.
It was another two weeks (on 1 June) before HMRC published its long-awaited guidance on tax adviser registration, setting out who must register as a tax adviser.
The requirement will have a wide impact for the legal community and parts of the business community. HMRC has confirmed that firms filing Stamp Duty Land Tax (SDLT) returns will have to register.
The guidance is comprised in HMRC’s internal manual on Mandatory Tax Adviser Registration, and is relevant to all ‘tax advisers’ who interact with HMRC on behalf of their clients (subject to exceptions).
Who must register?
Registration is required where a business interacts with HMRC in relation to another person’s tax affairs, in the course of business; and that service is paid for (s224 Finance Act 2026). The requirement applies even if your business is not UK-based.
Typically, this will include accountants and accountancy firms providing tax advice; financial advisers; agents who submits simple repayment claims on behalf of clients; and multi-disciplinary firms where tax advice is provided.
Probate practitioners who interact with HMRC for the purposes of inheritance tax filings, trusts etc will clearly need to register.
There is a very low bar for what it means to interact with HMRC for the purposes of registration. Simply contacting or messaging HMRC – even on a one-off occasion - can amount to interacting, triggering mandatory registration.
Conveyancers
Notably, conveyancers who interact with HMRC are within scope. The manual states: “Submitting an SDLT return on behalf of a client is assisting with a document that HMRC is likely to rely on to determine a person’s tax position and therefore constitutes interaction with HMRC in relation to tax.” [emphasis HMRC’s]
Further, it makes clear that outsourcing the filing of SDLT returns does not negate the registration requirement, rather both businesses will have to register.
Exemptions
There are two types of exemption from mandatory registration – statutory exceptions; and business activities/roles that do not meet the required definition of providing tax advice.
The guidance sets out a list of statutory exceptions (Sch 20 of the 2025 Act), including:
· Providing clients with tax/accounting software for use in relation to the client’s tax affairs;
· Acting in relation to customs duty, import VAT or excise matters
· Acting in relation to appeals to a court or tribunal
· Simply responding to a request by HMRC for information
· Businesses only providing non-domestic rating, council tax or property valuation services
Note that a business may not avoid registration by relying on an exception for part of its activity.
While HMRC does not provide an exhaustive list of other (non-statutory) exempt activities/roles that don’t meet the legal definition, it helpfully lists examples, such as:
· In‑house tax professionals preparing/filing tax returns solely on behalf of their employer and does not provide tax advice or services to external clients
· Insolvency practitioners legally required to interact with HMRC on behalf of insolvent individuals/businesses
· Charity employees and volunteers (and other free or pro bono work) giving free advice that is not in the course of business
If you are unsure whether your or your team fall within the exemptions from registration, take expert advice from tax solicitors to check your position. Bear in mind there may be sanctions (and you won’t be able to interact with HMRC) if you are required to register but fail to do so.
If you would like us to cover an issue in the next NGM Tax Law Newsletter, we would be pleased to hear from you