Under the new regime announced in the budget last year, any adviser (including firms) that interacts with HMRC on behalf of a client must be registered with HMRC as a tax adviser and meet minimum standards before doing so.

“Interacting with HMRC” includes submitting tax returns or other documents such as SDLT1s.

The requirement is being introduced via legislation in the Finance Bill 2025-26 and will take effect from May 2026 (with at least a 3-month transition period)

Although HMRC hasn’t yet published the final registration process (expected soon), draft guidance and policy papers suggest the following elements will be part of an application:

• Firm details
• Legal name of the firm
• Registered address
• Details of relevant individuals / senior managers
• Names of directors, partners or senior managers who have genuine control/influence over tax work.  All partners or directors should be assumed to fall within scope, subject to the size and make up of the firm.
• A statement confirming that both the firm and its senior managers meet the eligibility conditions.

To be accepted as a registered tax adviser, both the firm and relevant senior managers will need to satisfy minimum standards to include tax compliance, disclosure of HMRC engagement and conduct history and AML supervision, which the majority of conveyancing firms will already have.

A digital and non-digital application service will be provided by HMRC, and they will continue to have the option to request additional information where circumstances change and will demand to be notified if circumstances change to affect eligibility.

What you need to do now:

1. Undertake an internal compliance review to ensure the firm and senior managers meet eligibility conditions
2. Review and confirm the firms AML supervision status.
3. Identify who within the firm will qualify as a senior manager and who has control or influence over tax work, SDLT processes and compliance for supervision purposes. This will include review of your post exchange team if this is relevant to your firm.
4. Update your SDLT policy to ensure your SDLT processes align with HMRC ‘interaction’ definition.

Relationship with SRA regulation

Being SRA-regulated does not remove the requirement to register with HMRC.

However:

• SRA AML supervision will satisfy HMRC’s AML supervision requirement
• Most SRA-regulated firms should already meet HMRC’s eligibility standards
• Registration is primarily an administrative gateway, not a reassessment of professional competence

In short: SRA regulation helps, but does not replace the requirement for HMRC registration, and the penalties that will follow from failing to comply.

We will be updating firms as more information is released, but in the meantime if you have any questions please do not hesitate to get in touch.