HMRC tax adviser register: how the rules affect payroll professionals

Croner.

Roxanne Slevin MCIPP, policy officer at the Chartered Institute of Payroll Professionals, explains the new mandatory registration requirements for payroll providers from setting up an agent services accounts to new anti-money laundering oversight rules.

HMRC is ramping up its position on raising standards in the tax advice industry. Part of this push is to classify those who interact with HMRC on behalf of others as tax advisers.

Payroll only service providers will need to register for an HMRC agent services account (ASA) from 18 November 2026.

If you only operate payroll for your own company (in-house), or company group, you do not need to register.

To register for an ASA, businesses must be supervised by an anti-money laundering (AML) supervisor. Registration opened on 17 May and the final date to be registered is 18 February 2027.

The Chartered Institute of Payroll Professionals (CIPP) has been hard at work, staying on top of ever evolving interim legislation regarding the registration requirements to keep members updated.

What is a payroll only service provider?

Payroll only service providers are individuals or organisations that assist clients with their tax affairs by providing tax advice, acting as a tax agent, or helping with documentation likely to be relied upon by HMRC to determine someone’s tax position. It also applies to providers who work for, or who interact with HMRC on behalf of, the tax advisor.

This includes providers who do, or attempt to do, the following:

1.            Contact HMRC by telephone, post, or email

2.           Send a message to HMRC through a website or internet portal

3.           File a return, claim, notice or another document with HMRC (whether electronically or otherwise).

4.           Communicate with HMRC in any other way.

What is required?

To register online, businesses will need to operate as one of three entity types: a sole trader, a limited company, or limited liability partnership (LLP).

They must also establish whether the business already has an HMRC online services for agent’s account.

Where a business already interacts with HMRC for tax purposes, but does not yet have an agent services account (ASA), it will be asked to sign in using its existing agent credentials.

If a business does not currently advise on client’s tax affairs, it will be required to create new sign in credentials as an ‘agent’.

As part of the registration process, businesses must confirm their company details, including the company registration number and company name, and, where applicable, the partnership’s self-assessment unique taxpayer reference (UTR).

To complete registration for an ASA, businesses must also be supervised by an anti-money laundering (AML) supervisor. This requirement ensures that the business meets HMRC’s registration standards.

Businesses should continue to review HMRC’s guidance on relevant individuals and tax advisors for further information.

Registering with an anti-money laundering (AML) supervision body

Before applying, it is recommended businesses complete the anti-money laundering (AML), terrorist financing, and proliferation financing risk assessment, and put in place policies, controls, and procedures to manage and mitigate any risks they have identified.

To register, businesses will need to log into their Government Gateway account. It is best to have the following information readily available:

• email address

• bank details

• address of trading premises

• accountancy service provider

• details of individuals who are designated as responsible people in your business

Applications can be processed faster if sections are completed with as much information as possible. Applicants must also select the type of business and the relevant services; it is possible to choose multiple options.

Next, the declaration must be completed and the fees paid. It can take up to 45 days for new applications to be processed but it can take longer if extra information is needed. The applicant will then be emailed once a decision has been made.

Are there any exemptions?

Early draft legislation would have required pension administrators and practitioners to register. However, HMRC has now confirmed that pension administrators are exempt from the new registration requirement. This was in response to the feedback from the pensions industry. As a result, exemptions in Schedule 19 (exceptions) have been extended to include:

• pension scheme administrators

• pensions practitioners

• scheme managers of qualifying overseas pension schemes

• qualifying recognised overseas pension schemes

• responsible persons for employer-financed retirement benefit schemes

The rule of thumb is if there is no interaction with HMRC about the clients’ tax affairs, for instance providing information about annual allowance charges or holding pre-retirement information sessions, then there is no requirement to register.

What does this mean for your business?

Many payroll bureaus that have historically operated outside agent regulation will now be brought into HMRC’s formal agent framework. The tax advisor registration requirements will play a significant role in supporting businesses to remain compliant.

Non-compliance is being viewed with increased seriousness. The Finance Act has introduced a new statutory framework under ITEPA 2003, making risk management and compliance key considerations.

For example, from 6 April 2026, within the recruitment sector the message is clear: if an umbrella company, recruitment agency, or in certain circumstances end clients, fails to pay PAYE or National Insurance contributions (NICs), they may be held jointly and severally liable for the unpaid amounts.

In comparison, failure to meet tax adviser registration requirements will also result in an inability to act for clients, effectively preventing businesses from continuing to provide their services.

It is reasonable to expect that there will be ongoing compliance obligations, periodic reviews and audits, and additional fees to pay, however, these are comparatively small compared to the cost of non-compliance, which can have devastating consequences.

Last thoughts

Overall, this change signals an increase in regulation of payroll providers, greater alignment with the compliance obligations of tax agents, and a push towards higher professional and governance standards.

Businesses should be mindful that any activities not covered by the available exemptions, which involve providing tax advice to clients and interacting with HMRC on their behalf, will require registration with HMRC.

It is therefore advisable to begin the registration process as soon as possible and not to assume that AML applications will progress smoothly. For those wishing to sign up early, registration opens on 17 May 2026, with the final deadline of 18 February 2027.

About the author

Roxanne Slevin MCIPP is policy and research officer at the Chartered Institute of Payroll Professionals (CIPP)