Autumn Budget 2025: Tax Agent Registration

Opinion piece from Jo Summers, Partner and Head of Private Wealth & Tax, Jurit LLP, on the Autumn Budget 2025.

It’s been a bugbear of mine for years: that anyone can set themselves up as a tax adviser. No need for qualifications, insurance or indeed any knowledge of tax law.

I once sat through a meeting where unqualified tax advisers assured me they can avoid all tax on rental income.

How? “Easy, you just have it paid to a nominee.”

Pardon? “Well, the income doesn’t belong to the nominee, so they can’t be taxed, and it isn’t received by the owner so they can’t be taxed either.”

They say ignorance is bliss, but I don’t think that applies to tax.

So, I should be pleased HMRC are introducing a new registration system. It won’t cover all tax advisers, just those that want to ‘interact’ with HMRC on behalf of their clients. I’m not quite clear whether filing a client’s tax return counts as ‘interacting’ with HMRC.

Although we’ll need to wait for the legislation to be sure, it doesn’t initially sound that onerous.

There will be a new digital registration system, which will cover all taxes and replace the ‘multiple, often paper-based HMRC processes’ that create ‘complexity and administrative burden’ (HMRC’s words, self-knowledge is a good thing, right?).

The annual registration will provide assurances of HMRC’s ‘minimum registration provisions’ including AML supervision status. Plus, overseas advisers will need to provide ‘additional evidence (translated into English where necessary)’.

These new rules are due to come into effect in May 2026, with at least a three-month transition period.

So why am I not jumping around the room with joy?

Perhaps it’s the little comments in the Summary of Impacts section of HMRC’s Press Release. Such as the suggestion the new measures will bring in £40m from 2028 to 2029 onwards? Does that mean tax advisers will have to pay to register? Or does HMRC think that registering tax agents will somehow increase the taxes clients pay?

Then there’s the casual reference to taxpayers having to find someone new to represent them if their tax advisers ‘are no longer able to act on their behalf because they are either unable to satisfy the new registration requirements…or if their tax adviser is subject to sanction’.

There’s a similar reference later on to ‘Individuals may be impacted…..if their tax adviser is no longer able to act on their behalf or is suspended.’

So, clearly this is more than just a way of ensuring all tax agents are registered via a new online digital service, which covers all taxes.

For me, the big question is what will HMRC count as ‘minimum standards’ for corresponding with HMRC on clients’ tax affairs? Will that be related to qualifications, or will there be a Continuing Professional Development requirement?

And in what circumstances will HMRC be able to suspend or sanction tax advisers?

I really hope this new registration system will never be used ‘against’ tax advisers, who have the temerity to disagree with HMRC’s interpretation of the tax rules!