United Kingdom: HMRC Standard for Agents | Research Credit Integrity Alliance

This page summarizes the HMRC standard for agents: what it is, who it covers, what it expects, and how it applies to advisers who help companies claim United Kingdom research and development (R&D) tax relief. It describes the standard only and makes no recommendation.

What the standard is

The standard for agents sets out HMRC's expectations of tax agents and tax advisers in their dealings with HMRC, and gives an overview of how HMRC will tackle the minority of agents who do not meet it.1 It does not replace anything in law or HMRC guidance, and it does not override legal professional privilege or the professional duties set by professional bodies.1 The standard was first published in February 2016 and was updated in 2018 and 2023. HMRC describes the updates as part of its work on raising standards in the tax advice market.1

Who it covers

The standard applies to all individuals and businesses who are tax agents, in the United Kingdom or elsewhere, acting professionally in relation to the tax affairs of others. It applies to all their dealings with HMRC, and uses "agent" to mean both tax agents and tax advisers.1 HMRC's list of those covered includes:1

accountants and bookkeepers;
agents who only file tax returns and related documents;
agents who act for clients but do not give any tax advice;
legal and other professionals giving tax advice alongside other work; and
agents who assist clients in making claims for any tax repayment or relief.

HMRC says the list is not complete. The standard does not apply to trusted helpers.1

How it applies to R&D advisers

An adviser who helps a company prepare or submit an R&D claim falls within the description of an agent who assists clients in making claims for relief.1 HMRC states that more than 90 percent of R&D claimants have an authorized agent acting for them.2

HMRC's R&D forms reach beyond the agent who files the return. The additional information form 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 given information for or completed the online forms or the Company Tax Return.3 An agent who completes that form for a company must do so through an agent services account.3 See Additional Information Form and Preparer identification.

HMRC also states that it does not regulate tax agents, including those who advise on R&D claims, and that a customer who uses an agent remains responsible for its own tax affairs.2

The professional bodies

HMRC estimates that around 65 percent of agents are members of professional bodies.1 It recognizes and endorses the Professional Conduct in Relation to Taxation guidance used by the largest accountancy and tax bodies, and its standard focuses on three of the five fundamental principles in that guidance: integrity, professional competence and due care, and professional behavior. The two not specifically covered are objectivity and confidentiality.1

HMRC expects all agents who deal with it to keep to its standard, whether or not they belong to a professional body. It states that if agents meet their professional body's code of ethics, the standard should not place further requirements on them.1 See Professional body rules.

What the standard expects

The standard groups its expectations under four headings. The items most relevant to R&D claims are:1

Heading	Expectations relevant to R&D claims
Integrity (4.1)	Be straightforward and honest; respond promptly when HMRC uses information powers; do not suggest or imply that HMRC endorses the agent or that the agent acts for HMRC; make the identity of the agent or business clear
Professional competence and due care (4.2)	Keep knowledge of the relevant tax areas correct and up to date; work to prevent errors in clients' calculations or claims and avoid including figures in returns or claims which are unsubstantiated or speculative; keep contemporary records of advice; take reasonable steps to make sure third party input, such as software or specialist advice, gives accurate results
Professional behavior: legal compliance (4.3.1)	Keep own tax affairs up to date; register under and follow the Money Laundering Regulations 2017; comply with data protection law and with other relevant law and codes, such as consumer protection law and the advertising code of the Committee of Advertising Practice
Professional behavior: interaction with HMRC (4.3.2)	Work constructively with HMRC in investigations and enquiries; use prescribed HMRC forms or include the same information; access client data only through an authorized agent services account
Professional behavior: interaction with clients (4.3.3)	Make sure communications and advertising are fair, clear and accurate and do not mislead or conceal material facts; make terms of engagement clear and simple; agree them before acting; offer a reasonable cancellation period
Tax planning (4.4)	Act lawfully; base planning on a realistic view of the facts and a credible view of the law; do not promote arrangements contrary to the clear intention of Parliament

The standard uses "must" for some items, such as the rules on advertising and on not asking clients for their HMRC sign in details, and "should" or "we expect" for others.1

Fees and terms of engagement

The standard says terms of engagement should be as clear and simple as possible, in particular about:1

how the agent is to be paid for its services;
how any repayment of tax will reach the client, and on what conditions;
the deductions the agent will make from any repayment it handles for the client; and
the client's right to withdraw a nomination for repayment at any time before the repayment is made.

The standard asks for the payment basis to be explained. It does not set or prohibit any particular basis of charging.1 For R&D claims made on or after 1 April 2024, HMRC will generally pay R&D tax credits only to the claimant company, subject to exceptions for connected party nominees and exceptional circumstances.4 See Fee rules.

How HMRC upholds the standard

HMRC considers action against agents who do not meet the standard case by case, and in most cases seeks to work with the agent first. If the agent does not respond, or the issue is serious, it takes stronger action. Its options include blocking access to its agent services, dishonest tax agent conduct notices with possible penalties and publication, criminal investigation, and refusing to deal with an agent. Where appropriate, it informs the agent's professional body in a Public Interest Disclosure.1

For R&D claims in particular, HMRC describes these further steps:25

Measure	Description
R&D Anti-Abuse Unit	Since 2023, working with the Advertising Standards Authority to remove false advertising by agents claiming to be HMRC approved, and contacting agents not registered for anti-money laundering supervision2
R&D Agent Educational Model	Launched in January 2024. Agents identified as submitting multiple claims with similar risks are assigned an Agent Relationship Manager. HMRC says this is not accreditation2
R&D Professional Bodies mailbox	A route for professional bodies to raise R&D matters and breaches of standards2
Reporting route	Agents and accountancy professionals can report another agent suspected of poor R&D service standards, such as misleading information, poor technical knowledge or dishonest behavior5

Two statutory regimes now sit alongside the standard. Since 1 April 2026, HMRC can charge a penalty on a tax adviser for sanctionable conduct, meaning conduct intended to bring about a loss of tax revenue.6 Paid advisers who interact with HMRC on behalf of clients must register for an agent services account, with the requirement introduced in stages.7 See Adviser registration and Penalties.

Sources

HM Revenue and Customs, The HMRC standard for agents (updated 9 February 2026), sections 1, 1.1, 2, 2.1, 2.2, 3.2, 4.1, 4.2, 4.3.1, 4.3.2, 4.3.3 and 4.4. https://www.gov.uk/government/publications/hmrc-the-standard-for-agents/the-hmrc-standard-for-agents (accessed 11 October 2026). Back
HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), section 2.5. https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026). Back
HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief (last updated 26 September 2025), sections "Who can submit" and "Contact details". https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026). Back
HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD81805, "R&D tax relief: conditions to be satisfied: restriction of nominations and assignments" (updated 25 August 2026), sections "Explanation of terms" and "Restriction of nominations (CTA09/S1142D)". https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird81805 (accessed 11 October 2026). Back
HM Revenue and Customs, Reporting poor R&D tax relief service standards (published 26 September 2025). https://www.gov.uk/guidance/reporting-poor-rd-tax-relief-service-standards (accessed 11 October 2026). Back
HM Revenue and Customs, Compliance Handbook, CH176100, "Sanctionable conduct by tax advisers: Overview", and CH176140, "Commencement date" (manual updated 7 October 2026). https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch176100 (accessed 11 October 2026). Back
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" and "Who needs to 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