Unregulated claim preparers | Research Credit Integrity Alliance

Key points

In the United States anyone who prepares federal tax returns or refund claims for compensation must hold a preparer tax identification number, but a professional credential is not required to prepare them.12
In the United Kingdom, HMRC has said that almost anyone can start providing tax advice and services, and HMRC is now introducing, in stages, a requirement for paid advisers who deal with HMRC to register for an agent services account.34
Revenue in Ireland states that it does not operate any system for approving tax agents or advisors.5
Canada does not set a credential for SR&ED claim preparers, but requires the claimant to report who prepared the claim and how they were paid.6
Singapore lets companies authorize third parties such as tax agents to deal with IRAS on their behalf.7

Why this matters

A research and development tax claim is usually prepared with help. The help may come from an accountant, a lawyer, a specialist R&D adviser, or someone with no professional qualification at all. Whether that person needs a license, a registration or nothing at all depends on the country.

This article describes the position in each of the five countries this site covers, using the tax authorities' own guidance and legislation. It describes the rules only. It does not compare their merits, and it makes no recommendation for any country other than the United States. For the US federal rules on professional conduct, see Professional standards and their limits.

United States

Who may prepare. The IRS states that anyone who prepares or assists in preparing federal tax returns for compensation must have a valid preparer tax identification number (PTIN).1 The Internal Revenue Code requires any return or claim for refund prepared by a tax return preparer to bear the preparer's identifying number.8 A tax return preparer is any person who prepares for compensation any return of tax or any claim for refund, and preparing a substantial portion of a return or claim counts.9

Credentials. The IRS identifies three credentials that carry unlimited representation rights: enrolled agents, certified public accountants and attorneys.2 It also describes preparers who have an active PTIN but no professional credentials and do not take part in the voluntary Annual Filing Season Program. The IRS says these preparers are authorized to prepare tax returns, that this is the only authority they have, and that they have no authority to represent clients before the IRS except regarding returns they prepared and filed on or before December 31, 2015.2

Registration rules struck down. In 2011 Treasury and the IRS issued rules requiring paid tax return preparers to become registered tax return preparers subject to Circular 230. The courts held that Treasury lacked statutory authority to regulate tax return preparation as practice before the IRS (Loving v. IRS, 742 F.3d 1013 (D.C. Cir. 2014)).10 In December 2024 Treasury proposed removing the registered tax return preparer provisions from Circular 230.10

Refund claims. A federal district court has held that the IRS lacks statutory authority to regulate the preparation and filing of ordinary refund claims, meaning claims filed after the original return but before an audit (Ridgely v. Lew, 55 F. Supp. 3d 89 (D.D.C. 2014)).11 A business claiming a research credit it missed in an earlier year does so by a claim for refund.12

Penalties. Paid preparers are subject to the preparer penalties in section 6694 of the Code whether or not they hold a credential. A preparer who prepares a return or refund claim with an understatement due to an unreasonable position that they knew or should have known about owes the greater of $1,000 or 50 percent of the income derived from it.13

United Kingdom

Who may prepare. HMRC's 2024 consultation on raising standards in the tax advice market stated that almost anyone can start providing tax advice and services to clients and can do so with limited or no oversight if they are not a member of a professional body.3 The consultation stated that anti-money laundering supervision, by HMRC or a professional body supervisor, was the only legal requirement needed to set up in business and provide tax advice and services.3 It listed specialist R&D agents among the practitioners within the scope of its proposals.3

Registration since 2026. HMRC now states that if you interact with HMRC about someone else's tax affairs and get paid for it, it considers you a tax adviser who must register for an agent services account.4 Interaction includes sending returns, claims or other documents.4 The requirement is being introduced in stages, with later registration windows opening on 18 August 2026, 18 November 2026 and 31 December 2026 for particular groups.4 To register, a business must show that it is supervised for anti-money laundering purposes, and it and certain individuals must not, for example, have relevant outstanding returns or unpaid tax, relevant unspent convictions for fraud or tax offences, or be subject to certain HMRC sanctions.14 HMRC's published conditions do not include a qualification requirement.14

Identifying the adviser on the claim. HMRC's additional information form, which must be submitted to support a claim for R&D relief, asks for the contact details of all agents involved in the claim, including any agent who has given advice, analyzed costs, helped prepare technical assessments, or completed the online forms or the Company Tax Return.15 An agent completing the form must use an agent services account.15

Ireland

Who may prepare. Revenue's guidelines for agents and advisors state that Revenue does not operate any system for approving tax agents or advisors.5 An agent or advisor must have a Tax Advisor Identification Number (TAIN) before they can represent any Revenue customer, and the TAIN together with a client link form is the process by which a taxpayer authorizes an entity to act for it.5 Revenue says that neither a TAIN nor a tax clearance certificate is an approval or endorsement of an entity's conduct, experience or abilities.5

Registration. The TAIN application form asks the applicant to state the capacity in which they represent clients, with the options of accountant, solicitor, bookkeeper or intermediary for the Import One Stop Shop, and notes that TAINs are registered at Revenue's discretion and may be withdrawn at any time.16

Anti-money laundering. Revenue's guidelines state that an agent or advisor providing tax advice or tax returns who is not already regulated by a designated competent authority for anti-money laundering purposes falls under the supervision of the Anti-Money Laundering Compliance Unit of the Department of Justice.5

Canada

Who may prepare. The Income Tax Act defines a claim preparer of an SR&ED form as a person or partnership who agrees to accept consideration to prepare, or assist in the preparation of, the form, other than an employee doing so in the course of their employment.6 The definition does not refer to any qualification.6

Identifying the preparer. The Act makes the claimant and any claim preparer jointly and severally, or solidarily, liable for a $1,000 penalty where there is a false statement or omission in the claim preparer information required in an SR&ED form.6 That information covers the identity of the claim preparer and the arrangement under which the preparer agrees to accept consideration for preparing the form.6 A claim preparer is not liable if it exercised the care, diligence and skill that a reasonably prudent person would have exercised in comparable circumstances.6 The CRA's account of the measure is set out in What tax authorities changed.

Singapore

Who may prepare. IRAS allows companies to authorize employees or third parties, such as tax agents, through Corppass to access the company's myTax Portal account. A company that does so is deemed to have authorized them to handle its corporate income tax matters and correspond with IRAS on them.7 IRAS guidance consulted for this article does not set a qualification for tax agents.

Declaration by the company. The IRAS R&D claim form is signed by an authorized person of the company, who declares that the information is true and complete and acknowledges that penalties may be imposed for incorrect or false declarations.17 The form does not ask for details of any adviser.17

Summary

Country	Is a credential or registration required to prepare a claim for a fee?	Is the adviser identified to the tax authority?
United States	PTIN required; no professional credential required to prepare returns or refund claims12	Preparer's identifying number on the return or claim8
United Kingdom	Registration with HMRC for paid advisers who interact with HMRC; no qualification condition published414	All agents involved listed on the additional information form15
Ireland	TAIN needed to represent a client; Revenue does not approve agents5	Through the TAIN and client link5
Canada	No credential in the statutory definition of claim preparer6	Claim preparer identity and fee arrangement reported on the SR&ED form6
Singapore	No requirement found in the IRAS guidance consulted7	Not on the R&D claim form17

Rules change. Check the official sources below for the current position.

Sources

Internal Revenue Service, PTIN requirements for tax return preparers (page last reviewed or updated 16 October 2025). https://www.irs.gov/tax-professionals/ptin-requirements-for-tax-return-preparers (accessed 11 October 2026). Back
Internal Revenue Service, Understanding tax return preparer credentials and qualifications, sections on enrolled agents, CPAs, attorneys, Annual Filing Season Program participants and PTIN holders (page last reviewed or updated 29 January 2026). https://www.irs.gov/tax-professionals/understanding-tax-return-preparer-credentials-and-qualifications (accessed 11 October 2026). Back
HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration, consultation document published 6 March 2024, chapter 1 (Executive summary), chapter 3 and chapter 8. https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026). Back
HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC, sections "Who needs to register" and "When to register" (updated 3 September 2026). https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026). Back
Revenue Commissioners, Tax and Duty Manual Part 37-00-04b, Guidelines for Agents or Advisors acting on behalf of taxpayers (last reviewed September 2026), sections 1 and 2 and the section on anti-money laundering. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-37/37-00-04b.pdf (accessed 11 October 2026). Back
Government of Canada, Income Tax Act, RSC 1985, c 1 (5th Supp), subsections 162(5.1), (5.2) and (5.3). https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-162.html (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Digital services: Companies and tax agents, section on Corppass authorisation. https://www.iras.gov.sg/digital-services/companies-tax-agents (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6109, Identifying numbers, subsection (a)(4), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap61-subchapB-sec6109.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 7701, Definitions, subsection (a)(36)(A), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap79-sec7701.htm (accessed 11 October 2026). Back
Treasury Department and Internal Revenue Service, Regulations Governing Practice Before the Internal Revenue Service, notice of proposed rulemaking, 89 FR 104915 (26 December 2024), abstract and Background part A. https://www.federalregister.gov/documents/2024/12/26/2024-29371/regulations-governing-practice-before-the-internal-revenue-service (accessed 11 October 2026). Back
US District Court for the District of Columbia, Ridgely v. Lew, Civil Action No. 1:12-cv-00565 (CRC), Memorandum Opinion, 16 July 2014, pages 1 to 2 and 14 to 15. https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_12-cv-00565/pdf/USCOURTS-dcd-1_12-cv-00565-1.pdf (accessed 11 October 2026). Back
Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6694, Understatement of taxpayer's liability by tax return preparer, subsection (a)(1), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6694.htm (accessed 11 October 2026). Back
HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser, section "The registration conditions" (updated 2 October 2026). https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026). Back
HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief, sections "Who can submit" and "Contact details" (updated 26 September 2025). https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026). Back
Revenue Commissioners, Application for a TAIN, form RPC020223. https://www.revenue.ie/en/starting-a-business/documents/application-form-tain.pdf (accessed 11 October 2026). Back
Inland Revenue Authority of Singapore, Research and Development (R&D) Claim Form (YA 2019 and onwards), Part 4 Declaration. https://www.iras.gov.sg/docs/default-source/uploadedfiles/pdf/rnd-claim-form-(ya-2019-n-after).pdf (accessed 11 October 2026). Back