HMRC is the anti money laundering supervisor for accountants, bookkeepers, tax advisers and auditors who are not supervised by one of the professional bodies in Schedule 1 to the Money Laundering Regulations 2017. Firms register online, pay a one off application fee plus an annual fee for each premises and a fee for each approval check, and follow the same CCAB sector guidance as professionally supervised firms.

Who does HMRC supervise in the accountancy sector?

Regulation 7(1)(c)(iv) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) makes HMRC the supervisory authority for auditors, external accountants and tax advisers who are not supervised by a professional body listed in Schedule 1. Regulation 55(3) lets HMRC keep registers of those businesses, and HMRC calls them accountancy service providers.

HMRC’s registration guidance describes accountancy service providers as:

  • auditors who carry out statutory audit work;
  • accountants who provide accountancy services to clients, including professional bookkeeping and accounts preparation;
  • tax advisers and consultants who advise clients on their tax affairs or help complete and submit returns;
  • payroll agents that provide accountancy services or tax advice;
  • customs practitioners, freight forwarders and similar businesses if they provide accountancy or tax services.

Insolvency practitioners are excluded because their authorising body supervises them. In practice this often means bookkeepers and tax return preparers without professional body membership, and practices whose owners do not hold a practising certificate with a supervising body. The FCA estimates that HMRC supervises around 18,000 accountancy businesses and trust or company service providers. How a firm ends up with one supervisor rather than another is covered in choosing and registering with an AML supervisor.

How does registration with HMRC work?

Applications go through HMRC’s online service. HMRC’s manual says a sole proprietor can use a personal Government Gateway user ID or GOV.UK One Login, while a partnership, company or LLP should use the business’s own account. HMRC then communicates through secure messages in that account, and failing to act on a secure message, for example about an unpaid annual fee, can lead to the registration being cancelled.

The application must list every premises from which regulated activity is carried on. Premises used only for storing records, training or generally managing staff need not be registered, nor do premises outside the UK. Accountancy service providers may carry on business while the application, including approval checks on beneficial owners, officers and managers, is decided. Under regulation 59(2) HMRC must notify its decision within 45 days of receiving the application or any further information it requested.

After registration, HMRC expects material changes, such as a new beneficial owner, officer or manager, a new branch, a change of bank account or address, to be notified within 30 days. A change of nominated officer or compliance officer must be notified within 14 days.

What does HMRC supervision cost?

HMRC changed its fees from 1 December 2025. Its published fees are:

Fee Amount When paid
Application fee £300 Once, on first registration, non refundable
Premises registration fee £400 per premises On application
Approval process fee £40 per person tested For each beneficial owner, officer or manager
Annual declaration fee £400 per premises Each registration year

Premises added in the second half of a registration year attract half the fee, and no refund is given for premises removed. A business with turnover below £5,000 can apply for a small business reduction: it pays the full fees and then receives a £500 refund once its application or annual declaration is accepted. If a registration is cancelled, including for unpaid fees, the £300 application fee is payable again on reapplication. Regulation 102 allows HMRC to set charges to cover its supervision costs, including a charge for each premises.

What does the approval check involve?

Sole practitioners and the beneficial owners, officers and managers of an accountancy service provider must pass an approval check. HMRC checks whether each person has an unspent conviction for a relevant offence listed in Schedule 3 to MLR 2017, in any jurisdiction, using the applicant’s declaration, its own records and police records. HMRC recommends that firms screen new officers and managers with at least a basic DBS check and a signed declaration about overseas convictions. The legal requirement and the barring offences are explained in approval of owners and managers under Regulation 26.

Which guidance do HMRC supervised firms follow?

HMRC does not write separate rules for accountants. Its manual at AMLG2000 says guidance for accountancy service providers is published by the CCAB on behalf of the professional bodies and agreed with HMRC and HM Treasury. HMRC’s accountancy sector page links to the 2026 CCAB guidance and, since January 2026, to an HMRC document on risks common to accountancy service providers. HMRC’s own manual for supervised businesses also covers topics that apply across sectors, such as identity verification at AMLG11400. See the CCAB AML guidance.

How does HMRC supervision differ from a professional body?

  • Who oversees the supervisor. Professional bodies are overseen by OPBAS within the FCA; OPBAS does not oversee statutory supervisors such as HMRC.
  • What is supervised. HMRC supervises compliance with the Regulations only. Professional bodies also regulate members’ wider conduct, a role the FCA says they will keep after AML supervision moves to the FCA.
  • How fees are set. HMRC charges per premises and per approval check rather than through membership or practising certificate fees.
  • How compliance is checked. HMRC carries out visits and office based checks by telephone or desk review. The interval between visits depends on the size and complexity of the business, its customers and its compliance record.
  • Sanctions. HMRC can impose financial penalties, prohibit individuals from management roles, publish censure statements, suspend or cancel registration and pursue criminal investigation, and it must publish details of penalties and sanctions, subject to exceptions.

Another point is visibility: HMRC publishes a Supervised Business Register that anyone can use to check whether a business is registered.

What does this look like for a small bookkeeper?

Illustration only. Priya runs a bookkeeping and self assessment business from home as a sole trader and has no professional body membership. She applies online with her personal Government Gateway account, registering her home office as one premises. Her first year fees are £300 application, £400 premises and £40 for her own approval check, a total of £740. In later years she pays the £400 annual declaration fee. If she later rents a separate office where client work is done, she must add it and pay for that premises too.

What mistakes do HMRC supervised firms make?

  • Missing secure messages because the email address on the account is out of date.
  • Appointing a new manager or taking on a new partner without telling HMRC within 30 days and paying for the approval check.
  • Leaving a branch or second office off the registration.
  • Assuming HMRC supervision is lighter: the same duties apply, including customer due diligence and a firm wide risk assessment.
  • Overlooking the planned move of HMRC’s accountancy population to the FCA, described in AML supervision reform.

Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.