Registration for the new Tax Adviser regime is now open.  I understand for those applying, if they haven’t previously had an agent services account, the process was time consuming, but they got there in the end.  For those of you looking to register over the coming weeks, HMRC has made a small but potentially important amendment to its guidance on mandatory tax adviser registration, published on 18 May 2026.

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The change relates to firms with six or more officers and the process for identifying the individuals who must be registered as "relevant individuals" for the purposes of the new regime.

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The revised guidance now states:

"If your business has 6 or more officers, first identify those who actually make strategic or management decisions about your tax advice work. Do not include all officers by default. In some cases, fewer than 5 officers will meet this definition. If this happens, you must choose additional officers so that you have at least 5 in total. You can choose which officers to include. They do not have to be the most senior or responsible for day-to-day tax advice."

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At first glance, this appears to be a relatively minor drafting amendment. However, the new reference to officers who make "strategic or management decisions about your tax advice work" provides useful clarification on HMRC's intended approach.

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The previous wording could be read as requiring firms simply to identify senior officers or managers. The revised guidance indicates that HMRC is concerned specifically with those exercising strategic or managerial oversight of the firm's tax advice activities, rather than everyone holding a management role within the business.

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For conveyancing practices, this distinction may be particularly welcome. A manager responsible for a post-completion team, SDLT submissions or operational supervision of conveyancing files would not automatically fall within the definition of a relevant individual merely because they manage staff. On HMRC's revised wording, the question is whether that individual makes strategic or management decisions about the firm's tax advice work.  So, for anyone who has attended my most recent seminars focusing on the new ‘Tax Adviser Regime’ it seems with larger firms that ‘Colin from Accounts’ might be spared.

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Equally, a head of department or operations manager who has no role in determining how tax advice is provided, supervised or governed within the firm may not be a relevant individual for these purposes.

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The amendment does not fundamentally alter the registration regime and HMRC has provided little additional detail beyond the revised wording itself. Nevertheless, it offers a helpful indication that firms should focus on those who influence the firm's tax advice function, rather than automatically including every officer, manager or supervisor within the organisation.

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For firms reviewing their registration obligations, the practical exercise is therefore likely to be less about organisational hierarchy and more about identifying who genuinely makes strategic or management decisions relating to the firm's tax advice activities. For many conveyancing practices, that may be a considerably smaller group than initially anticipated.