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United Kingdom: Adviser registration

Who may prepare a UK R&D tax relief claim for a fee, the mandatory registration of tax advisers with HMRC introduced in 2026, and the conditions and sanctions that come with it.

Rules as at

This page summarises rules in United Kingdom as at Oct 11, 2026. It is not legal advice and may not reflect later changes. Check the official sources listed below.

This page explains who may prepare a United Kingdom research and development (R&D) tax relief claim for a fee and whether they must register with HMRC. It describes the rules only and makes no recommendation.

Summary

Question Position as at 11 October 2026 Source
Must a paid adviser who sends an R&D claim to HMRC register? Yes, for an agent services account, unless an exception applies HMRC guidance and the Finance Act 20261Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026).
Is a qualification or professional body membership required? Not among the registration conditions HMRC lists HMRC registration conditions3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026).
Can the company make its own claim? Yes, a representative of the company can complete the forms HMRC claim guidance4Source 4HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (last updated 31 October 2024), section "Who needs to submit the form". https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).5Source 5HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).
Can an agent submit the additional information form without an agent services account? No HMRC claim guidance5Source 5HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).

Before 2026

HMRC's 2024 consultation on the tax advice market stated that anti-money laundering supervision, by HMRC or a professional body, was then the only legal requirement needed to set up in business and provide tax advice and services. It said this meant practitioners could enter the market without demonstrating minimum standards of competence.6Source 6HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), section "The limitations of the partial regulatory framework", and section "How this approach could work: who should be regulated?", Figure 2 and "Groups in scope". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026). The consultation listed specialist research and development agents among the practitioners that would be in scope of the regulatory requirements it proposed.6Source 6HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), section "The limitations of the partial regulatory framework", and section "How this approach could work: who should be regulated?", Figure 2 and "Groups in scope". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

The government's response said respondents were strongly in favor of mandatory registration, and that from April 2026 all tax advisers who interact with HMRC on behalf of a client would have to register with HMRC before doing so.7Source 7HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration, consultation outcome, "Detail of outcome" (updated 30 October 2024). https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

Who must register

HMRC's manual on mandatory tax adviser registration explains that, for this purpose, a tax adviser is defined in section 224 of the Finance Act 2026 as an organization or individual which, in the course of a business, assists other persons with their tax affairs.2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026). Assistance includes advising a client on tax, acting as agent for a client, and assisting with the preparation of any document that HMRC is likely to rely on in determining a person's tax position.2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026).

Registration is required only where a business both interacts with HMRC about another person's tax affairs and is paid for that service.2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026). Interaction includes filing a return, claim, notice or other document with HMRC, contacting HMRC by telephone, post or email, and making payments.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026). The legal entity providing the service registers; individual employees do not register separately, but HMRC carries out checks on certain "relevant individuals" in the business.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026).

HMRC states that a business may need to register even if it does not see itself as a tax adviser, if helping people with their tax affairs is not its main business, or if it acts for only one client.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026). Overseas businesses must also register.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).

Who does not need to register

HMRC lists exceptions. They include interacting with HMRC only as an employer or in-house tax team, about the business's own group's tax affairs, giving tax advice for free, responding to an HMRC request for information, and representing a client in appeals to a court or tribunal.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).

What this means for R&D claims

An adviser that is paid to send an R&D claim, a claim notification or an additional information form to HMRC for a company is interacting with HMRC about that company's tax affairs. HMRC's guidance already requires an agent completing the additional information form to log in to an agent services account first.5Source 5HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026). An adviser that advises on a claim but does not interact with HMRC is outside the registration requirement, because registration depends on interaction.2Source 2HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026). It is still a tax adviser for other purposes, including the sanctionable conduct rules described on Penalties.8Source 8HM Revenue and Customs, Compliance Handbook, CH176160, "Sanctionable conduct by tax advisers: who is a tax adviser" (manual updated 7 October 2026). https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch176160 (accessed 11 October 2026).

When to register

Registration is being introduced in stages:

Group Registration window opens
Businesses that already have a Self Assessment or Corporation Tax agent account 18 August 20261Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).
Businesses that only provide third-party payroll services 18 November 20261Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).
Financial services organizations 31 December 20261Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).
Everyone else, including those new to the market Now1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).

A business has three months from the date its window opens to apply, and can continue to interact with HMRC for clients during those three months and while HMRC considers the application.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026). A business that already has an agent services account does not need to register again.1Source 1HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).

The registration conditions

The business must provide evidence that it is supervised for anti-money laundering purposes, by HMRC or a supervisory body, before it applies.3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026). The business must not:

  • have relevant outstanding tax returns or unpaid tax, unless covered by a payment plan;
  • be subject to an HMRC decision refusing to interact with it;
  • be subject to an anti-avoidance sanction or a stop notice;
  • have relevant unspent convictions for fraud or tax offenses;
  • be formally insolvent; or
  • be suspended or permanently banned from registering with HMRC.3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026).

The same conditions apply to relevant individuals, who also must not be disqualified from acting as a director in the UK or overseas.3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026). For a business with five officers or fewer, all officers are relevant individuals; a larger business identifies those who make strategic or management decisions about its tax advice work, with a minimum of five.3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026).

The listed conditions do not include a tax qualification or membership of a professional body.3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026). HMRC continues to check that registered businesses meet the conditions, and a registration may be suspended if they do not.3Source 3HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026).

Sanctions

HMRC states that the sanctions provisions are in sections 232 to 246 of the Finance Act 2026.9Source 9HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026). They include:

  • Suspension of registration, which prevents the adviser from interacting with HMRC for clients;9Source 9HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026).
  • Financial penalties for prohibited interactions while subject to a compliance notice, normally £5,000 for each interaction, rising to £10,000 in specified cases;10Source 10HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30400, "Sanctions and safeguards: financial penalties for prohibited interactions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30400 (accessed 11 October 2026).
  • Ineligibility orders; and
  • Publication of details of sanctioned advisers where the legislation permits.9Source 9HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026).

HMRC says advisers will be given a chance to put things right or make representations before a sanction takes effect, and that there are rights of review and appeal against specified decisions.9Source 9HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026).10Source 10HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30400, "Sanctions and safeguards: financial penalties for prohibited interactions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30400 (accessed 11 October 2026). A person is not liable to a financial penalty for a prohibited interaction if it has a reasonable excuse.10Source 10HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30400, "Sanctions and safeguards: financial penalties for prohibited interactions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30400 (accessed 11 October 2026).

Who may prepare a claim

Registration governs who may interact with HMRC for a fee. It does not reserve R&D claim work to any profession. A claim notification can be completed by a representative of the company or by an agent acting for it, and the additional information form by a representative of the company or by an agent using an agent services account.4Source 4HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (last updated 31 October 2024), section "Who needs to submit the form". https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).5Source 5HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).

Sources

  1. HM Revenue and Customs, Check if and when you need to register as a tax adviser with HMRC (last updated 3 September 2026), sections "Changes to registration", "Who needs to register", "Who does not need to register", "When to register" and "What happens if you do not register". https://www.gov.uk/guidance/check-if-and-when-you-need-to-register-as-a-tax-adviser-with-hmrc (accessed 11 October 2026).             Back
  2. HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR10100, "Scope and requirement to register: who must register as a tax adviser" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar10100 (accessed 11 October 2026).        Back
  3. HM Revenue and Customs, Check if you meet HMRC's conditions to register as a tax adviser (last updated 2 October 2026), sections "Who needs to meet the conditions", "The registration conditions" and "After you've registered". https://www.gov.uk/guidance/check-if-you-meet-hmrcs-conditions-to-register-as-a-tax-adviser (accessed 11 October 2026).        Back
  4. HM Revenue and Customs, Tell HMRC you want to claim Research and Development (R&D) tax relief (last updated 31 October 2024), section "Who needs to submit the form". https://www.gov.uk/guidance/tell-hmrc-that-youre-planning-to-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).   Back
  5. HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), section "Who can submit". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).     Back
  6. HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), section "The limitations of the partial regulatory framework", and section "How this approach could work: who should be regulated?", Figure 2 and "Groups in scope". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).   Back
  7. HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration, consultation outcome, "Detail of outcome" (updated 30 October 2024). 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
  8. HM Revenue and Customs, Compliance Handbook, CH176160, "Sanctionable conduct by tax advisers: who is a tax adviser" (manual updated 7 October 2026). https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch176160 (accessed 11 October 2026).  Back
  9. HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30100, "Sanctions and safeguards: overview of HMRC's approach to sanctions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30100 (accessed 11 October 2026).     Back
  10. HM Revenue and Customs, Mandatory Tax Adviser Registration manual, MTAR30400, "Sanctions and safeguards: financial penalties for prohibited interactions" (manual updated 8 October 2026). https://www.gov.uk/hmrc-internal-manuals/mandatory-tax-adviser-registration/mtar30400 (accessed 11 October 2026).    Back