The UK’s HM Revenue & Customs (HMRC) will require anyone dealing with the department on a client’s behalf to register from May 2026.

The move follows a 2024 consultation, after which the government confirmed that all tax practitioners that plan to interact with HMRC on behalf of clients must register.

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Legislation to introduce the regime is included in the current Finance Bill.

The government describes this as a step towards “raising standards in the tax advice market” and has said the requirement will be backed by investment to ensure HMRC’s registration services are easy to use.

HMRC has issued initial guidance on who must register, how and when registration will take place, and the standards advisers need to meet.

The Institute of Chartered Accountants of Scotland (ICAS) is involved in ongoing discussions on implementation and guidance and has invited queries and feedback from members.

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According to an ICAS statement, any business that is paid to interact with HMRC regrading someone else’s tax affairs will have to register.

Interaction includes contact by phone, post or email, messages through the GOV.UK website or HMRC app, and sending returns, claims or other documents.

The legal entity that interacts with HMRC will be required to register. Individual employees will not need to register separately, although HMRC will carry out checks on certain individuals within the registered business.

Registration is required even if the business does not see itself as a tax adviser or works as a registered sole trader. Additionally, the registration has been made mandatory for businesses that interact with HMRC on behalf of one client or are based outside the UK.

However, businesses which run payroll in-house, work on intra-group tax work and offer free tax advice are exempted.

Additionally, no registration is needed where interaction is only on customs or import VAT; as a VAT representative; as a Northern Ireland tax representative; as a UK representative for Vaping Duty; or to represent a client in court or tribunal appeals.