Following anticipation earlier this year, HMRC has released further guidance on its forthcoming “Mandatory tax adviser registration with HMRC” policy.

As of 17 February 2026, two guidance notes have been published:

Check if and when you need to register as a tax adviser with HMRC - GOV.UK

Check if you meet HMRC's conditions to register as a tax adviser - GOV.UK

Introduction of the New Registration System

From 18 May 2026, HMRC will introduce a new online registration system linked to Agent Services Accounts. This will replace the current registration process.

Where an adviser already holds an Agent Services Account, this will be migrated to the new system and re-registration will not be required.

HMRC has confirmed that the registration requirement will be introduced in stages. The timing of registration will depend on the nature of the adviser’s activities and individual circumstances.

Who needs to register?

The guidance makes clear that a person or organisation will be regarded as a tax adviser if they:

• Interact with HMRC in relation to another person’s tax affairs; and

• Receive payment for doing so.

“Interaction” is defined broadly and includes communication by post, email, telephone, through the GOV.UK website or HMRC app, and the submission of claims, tax returns or other documentation.

Importantly, the obligation to register rests with the legal entity that interacts with HMRC. Individual employees within a firm will not be required to register separately where they act on behalf of their employer unless classed as 'relevant individuals' which is determined by the number of officers the business has. 

In summary:

• Conveyancers are likely to be affected

• The legal entity (not individual employees) must register

• Existing Agent Services Accounts will be migrated

• Registration will be phased, and HMRC is expected to contact firms directly

Although this guidance provides further clarity on the policy, several points remain uncertain:

• The position regarding SDLT

• Clarity on transition periods for conveyancing practices

• Whether exemptions or special rules will apply to SRA or CLC regulated firms

Further updates from HMRC are expected as implementation approaches. Please get in touch with us if you would like to discuss any of the changes.