A guide for bookkeepers and payroll agents
As part of the Finance Bill 2025-26, HMRC is introducing a new requirement for all "Tax Advisers" to register with them and meet minimum standards. This shift is designed to formalise the tax advice market, ensuring that anyone acting as an intermediary meets a set of standards for conduct and compliance.
Important Status for Existing Agents: If you already have an Agent Services Account (ASA), you do not need to take immediate action. HMRC has confirmed there will be a separate, "lighter touch" transition process. They will contact you directly via your ASA when they require further information. Your priority right now is to ensure your ASA contact details are accurate and your own tax affairs are in order.
Are you a "Tax Adviser"?
Many bookkeepers and payroll specialists do not describe themselves as tax advisers. However, under the new legislation, you are likely to be classified as one if you interact with HMRC on behalf of a client and receive payment for these services.
HMRC considers you a Tax Adviser if you:
- File returns (VAT, CIS, PAYE, SAT, CT, etc.), claims, or notices with HMRC.
- Contact HMRC via telephone, post, email, or online portal on behalf of a client.
- Provide advice or assistance with any document that HMRC relies on to determine a client's tax position.
Note: Even if tax is not your primary business function, if you represent a client to HMRC, you must comply with these new rules to maintain your agent account.
The AML Foundation: A Current Requirement
This registration is not a replacement for your existing professional obligations. It is already a strict requirement that any holder of an Agent Services Account (ASA) must be supervised for Anti-Money Laundering (AML) by ICB, HMRC, or another recognised supervisory body.
When the new registration system launches, HMRC will use it to verify that your active AML supervision is in place. Ensuring your ICB membership and AML supervision are fully up to date is the single most important preparation you can make.
Relevant Individuals & Fitness Standards
While registration happens at the firm level, you must identify your "Relevant Individuals" - the people responsible for the management and direction of your practice. Their personal tax compliance will be vetted by HMRC.
A Familiar Process: BOOMs vs. Relevant Individuals
If you are already supervised for AML by ICB, you will be familiar with the concept of BOOMs (Beneficial Owners, Officers, and Managers). Currently, to hold an AML licence, your BOOMs must be approved by your supervisor, usually by providing a clean DBS check to prove they have no relevant criminal convictions.
The key difference: While the existing AML 'BOOM' check focuses on the criminal records of your key people, the new HMRC 'Relevant Individual' check adds personal tax liabilities to the list. For HMRC, it is no longer enough for a Director or Manager to be "criminally clean"; they must now also be "tax clean."
The Fit and Proper Test
HMRC will check that every Relevant Individual meets the following criteria:
- Tax Compliance: No outstanding tax returns and no overdue tax payments (unless a formal 'Time to Pay' arrangement is in place).
- Professional Conduct: No unspent convictions for relevant offences (such as fraud or dishonesty).
- Directorship Standing: Not currently disqualified from acting as a company director.
- Financial Integrity: No history of involvement in promoted tax avoidance schemes.
How This Affects Your Practice
The number of people you must name depends on the size of your business. The same people you have already declared as BOOMs for AML are likely the same people HMRC will now vet for tax debts.
Small Firms (5 or fewer Officers)
An "Officer" includes sole traders, statutory directors, or partners. You must name:
- Every single Officer of the firm, regardless of whether they perform tax work.
- Any senior employees who manage or make significant decisions regarding your tax or payroll services.
Large Firms (6 or more Officers)
Larger firms follow the Rule of Five. You must name:
- All individuals (Officers or employees) who manage or oversee the tax and payroll functions.
- The Top-up: If that list does not include at least five Officers (Directors/Partners), you must nominate additional Officers until you have reached a minimum of five.
Important Note: Spouse and 'Silent' Directors
Many bookkeeping practices are run as family businesses where a spouse is a co-director but does not work in the business. HMRC does not offer an exemption for 'silent' directors. If your spouse is a named Director of a small firm, they are a Relevant Individual. If their personal record is not clear (e.g., they have a debt from an unrelated venture), it could lead to the suspension of your practice's registration.
Registration Timeline
| Agent Category | Registration Window Opens | Mandatory Deadline |
|---|
| Existing ASA Holders |
N/A |
Wait for HMRC to contact you |
| New Agents (No existing account) |
18 May 2026 |
18 August 2026 |
| Payroll-Only Agents* |
18 May 2026 |
18 November 2026 |
*Defined as those who provide third-party payroll-only services and do NOT interact with HMRC in any other way.
What should you do now?
- Conduct an internal audit: Ensure every Director (including 'silent' ones) and senior manager has filed their personal returns and paid all liabilities.
- Update your ASA: Ensure your contact details are correct so you receive HMRC's transition notice.
- Verify AML: Ensure your ICB AML supervision is current.
- Wait for Guidance: Do not attempt to create a new registration if you already have an ASA; wait for HMRC to contact you.
Disclaimer: This information is based on current HMRC policy as of March 2026. Requirements may be revised as the Finance Bill 2025-26 reaches Royal Assent.
