HMRC is introducing significant reforms that will reshape how professionals interact with the tax authority on behalf of clients. With mandatory tax adviser registration coming into force—and the government confirming that conveyancers will not be exempt—the impact on the property sector is now unavoidable.
Full guidance is available here.
Why HMRC Is Introducing Mandatory Registration
From 18 May 2026, HMRC will launch a new online registration system for agent services accounts. This will replace the current registration process and is part of HMRC’s wider programme to improve oversight of those who assist others with their tax affairs.
HMRC’s goal is to:
- Raise standards across the tax advice sector
- Ensure anyone paid to interact with HMRC on behalf of others is visible and accountable
- Apply consistent checks to reduce risks around tax compliance
This registration requirement applies even if tax is not your main service, you only assist one client, or you do not consider yourself a tax adviser.
Who Must Register?
HMRC defines a tax adviser as anyone paid to interact with HMRC about someone else’s tax affairs. Registration is required at the legal entity level, although HMRC may conduct suitability checks on key individuals within a business.
Activities that bring you within scope include communicating with HMRC on a client’s behalf via:
- Telephone
- Post or email
- Messages through GOV.UK or the HMRC app
- Filing or submitting tax returns, claims, or other documents
You must register even if:
- You do not describe yourself as a tax adviser
- You are a sole trader or small firm
- You are based outside the UK but provide services to UK clients
Who Does Not Need to Register?
HMRC’s list of exempt groups includes:
- Employers or in‑house teams dealing only with their own payroll or internal tax matters
- Those providing unpaid tax assistance
- Insolvency practitioners or others legally required to interact with HMRC
- Software suppliers who do not communicate with HMRC for clients
- Agents dealing exclusively with customs, import VAT, or specialist Northern Ireland VAT roles
These exemptions do not cover conveyancers.
Why SDLT Work Brings Conveyancers Into Scope
HM Treasury has declined to exclude conveyancers from the new rules. This is because filing Stamp Duty Land Tax (SDLT) returns—a routine part of conveyancing—counts as interacting with HMRC about someone else’s tax affairs.
Several professional bodies have raised concerns:
- The Law Society has warned the requirement may slow property transactions and increase administrative complexity.
- The Council for Licensed Conveyancers (CLC) argued that the rules could duplicate existing regulation and lead consumers to believe conveyancers provide tax advice, even though they are not permitted to do so.
- HMRC’s guidance confirms conveyancers are not exempt.
The CLC has expressed disappointment, emphasising that conveyancers interact with HMRC to submit SDLT returns only, not to give broader tax advice. The concern is that the rules could raise compliance costs without improving consumer protection.
Registration Timelines
Registration will be rolled out in phases depending on the type of adviser or organisation. HMRC will contact existing agent services account holders if further information is needed.
Importantly, existing agent services account holders will not need to set up a new account, but may need to update or verify details.
Consequences of Not Registering
Firms that fail to register may find themselves unable to interact with HMRC on behalf of clients. Over time, HMRC may introduce compliance checks or penalties as part of its broader focus on raising standards in the tax advice sector.
What Conveyancing Firms Should Do Now
With confirmation that conveyancers fall within the scope of the new rules, firms should begin preparing for mandatory registration. Key steps include:
- Review your processes for SDLT submissions or any other HMRC interactions to ensure the business entity is ready to register.
- Check your supervisory body’s AML oversight, as HMRC will require evidence of supervision during registration.
- Audit your team structure, particularly in multi‑entity or group organisations, to determine who falls under HMRC’s definitions.
- Resolve any outstanding HMRC liabilities or overdue returns, which could otherwise block your registration.
- Update client onboarding and communications, as clients may have questions about the new HMRC checks and what the firm’s registration means for them.
- Keep your agent services account details up to date so HMRC can contact you when your registration window opens.