Tax adviser registration guide

HMRC tax adviser registration: do you need PI insurance?

No. Professional indemnity insurance (PII) is not one of HMRC’s conditions for registering as a tax adviser. The conditions in the Finance Act 2026 cover tax compliance, anti-money laundering (AML) supervision and checks on the people who run the business. PII can still be compulsory through your professional body, and clients may ask for it.

Part of: PI insurance for tax advisers

Who has to register with HMRC as a tax adviser?

You must register if you interact with HMRC about someone else’s tax affairs and get paid for it. Interaction includes calls, post, email, online messages, payments and sending returns, claims or other documents. The legal entity that deals with HMRC registers, so a sole trader registers as an individual and employees do not register separately. HMRC’s guidance says you must register even if you do not see yourself as a tax adviser, tax work is not your main business, or you act for only one client.

The rule is in section 223 of the Finance Act 2026: a tax adviser may not interact with HMRC about a client’s tax affairs unless registered, or unless an exception in Schedule 20 applies. You register through an agent services account, which HMRC describes as “how tax advisers access HMRC’s online services”.

You do not need to register if you only interact with HMRC:

• as an employer or in-house tax team, or about your own group’s tax affairs;
• for free, for example through a charity or for friends and family;
• because the law requires you to, for example as an insolvency practitioner;
• to answer an HMRC information request, or to provide accounting, tax or payroll software;
• on customs or import VAT, or in certain representative roles such as VAT representative;
• in court or tribunal appeals, or on business rates, council tax or property valuation.

If a business also does work that is in scope, it must register. HMRC’s manual says a business “cannot rely on an exception for part of its activity to avoid registration” (MTAR10300).

When do you have to register?

Each group has a three-month window to apply, and the requirement applies to it from the day after its window closes. You can keep acting for clients during your window, and while HMRC considers an application made in it.

Who	Registration window	Rules apply from
New advisers, and advisers without an agent services account, Self Assessment account or Corporation Tax account	18 May to 17 August 2026	18 August 2026
Advisers with a Self Assessment or Corporation Tax account but no agent services account	18 August to 17 November 2026	18 November 2026
Advisers who only provide payroll services and have no agent services account	18 November 2026 to 17 February 2027	18 February 2027
Financial services organisations without an agent services account	31 December 2026 to 31 March 2027	1 April 2027

The windows come from HMRC’s manual (MTAR10800) and the start dates from the Appointed Days Regulations (SI 2026/807). The payroll and financial services windows apply only to businesses that do nothing else.

If you already had an agent services account, you do not need to apply again. The regulations treat an adviser who had one immediately before 18 August 2026 as registered from that date, and HMRC will contact you through the account if it needs more information (MTAR30700). If you missed your window, HMRC says register now.

What conditions does HMRC check?

Section 227 of the Finance Act 2026 sets three registration conditions:

1. Compliance and fitness. The business and each “relevant individual” must not have relevant tax overdue or returns outstanding (tax under a payment plan is allowed), face an HMRC refusal to deal with them, be subject to certain anti-avoidance measures, be suspended or banned, be disqualified as a director, have an insolvency practitioner acting, or have an unspent conviction for a relevant offence.
2. AML supervision. The business must be registered with an anti-money laundering supervisor. HMRC’s manual says having applied for supervision is not enough (MTAR20200).
3. Relevant individuals. A business with six or more officers must nominate enough officers to have at least five relevant individuals. If a business has five officers or fewer, HMRC treats all of them as relevant individuals.

Once registered, you must keep meeting the conditions and act in line with HMRC’s standard for agents. If the conditions stop being met, HMRC gives you 30 days to put things right (60 for unpaid tax) before suspending you, and behaviour below the standard can bring a suspension of up to 12 months (HMRC sanctions guidance).

Is PI insurance a condition of HMRC registration?

No. None of the three conditions in section 227 mentions insurance, and neither does HMRC’s list of registration conditions. HMRC’s standard for agents sets expectations on integrity, professional competence and professional behaviour. It does not set an insurance requirement.

This was a deliberate policy choice. In March 2021 the government consulted on making PII compulsory for tax advisers. Its summary of responses of 30 November 2021 said the government “will therefore not be proceeding with the introduction of a requirement for tax advisers to hold PII at this time”. It said consultation responses showed that compulsory PII on its own would not be an effective way to raise standards or have a meaningful impact on consumer redress, and that adding many new and potentially risky advisers to the insurance pool could increase premiums for all advisers.

So registration decides whether you may deal with HMRC for clients; insurance decides who pays if a client says your work cost them money.

When is PI insurance compulsory for tax advisers?

Mainly through professional bodies. If you belong to one, its rules apply whatever HMRC requires.

Body	Who must hold PII	Minimum cover	After you stop
CIOT and ATT (regulations effective 1 January 2023)	Members in practice, for their firm	£1 million each and every claim. If gross fee income is under £400,000: the greater of 2.5 times fee income and £100,000. Excess no more than £30,000 per principal.	At least six years after ceasing to practise
ICAEW (regulations effective 1 September 2024)	Members with a practising certificate, firms in public practice and the other categories in regulation 2.1	£2 million for a single claim and in the aggregate. If gross fee income is under £800,000: 2.5 times fee income, with a minimum of £250,000. Aggregate excess no more than the higher of £3,000 or 3% of fee income.	At least two years, then all reasonable steps to keep cover for a further four years

Sources: CIOT PII Regulations and ICAEW PII Regulations. The CIOT and ATT regulations also say the policy must cover “all civil liability, including costs and expenses, incurred in connection with the provision of or the offering of taxation services”. Employees need not hold cover in their own name, and a subcontractor needs its own cover unless the contracting firm confirms in writing that it has named the subcontractor on its policy and its insurer has waived subrogation.

If you are not a member of a professional body, HMRC’s registration rules do not make you hold PII. You still carry the liability if a client says your advice or a missed deadline cost them money, and clients can make cover a condition of working with you.

What does registration change for your PI risk?

Registration brings new sanctions that fall on your business, not your clients:

• A first prohibited interaction while unregistered or suspended brings a formal compliance notice.
• After that, each prohibited interaction brings a £5,000 penalty. A fifth penalty within two years of the first is £10,000 with a 12-month ban, and an interaction during a ban brings a £10,000 penalty and a permanent ban.
• If your registration is suspended for more than 30 days, or you are banned, you must take reasonable steps to tell your clients within 30 days, or face a £5,000 penalty for each client you should have told.

For three months from the date you need to register, you will not be sanctioned if you have applied and are awaiting a decision (HMRC sanctions guidance).

PI insurance is designed for civil liability to clients and others who rely on your work. Do not assume it will pay a penalty HMRC charges your firm under these rules. Two practical points:

• Tell your broker about problems. Before a policy is entered into, including at renewal, the Insurance Act 2015 requires a fair presentation of the risk, including disclosure of “every material circumstance” you know or ought to know (section 3). A suspension, sanction or refused application is the kind of thing to raise.
• Check who your policy covers. Registration is by legal entity. Make sure the business named on your PI policy is the one that registers and does the work.

Apex arranges professional indemnity insurance for tax advisers and accountants. Cover is always subject to the policy terms. See our tax advisers’ PI guide and accountants’ PI guide.

Sources

• gov.uk: Who must register (paid + interacts with HMRC about someone else’s tax affairs); what counts as interaction (phone, post, email, GOV.UK/HMRC app messages, payments, returns/claims/documents); legal entity registers, employees do not; must register even if not seen as tax adviser, not main business, one client; full list of who does not need to register; existing agent services account holders need not register again; missed window or new to market: register now.
• gov.uk: Registration conditions (AML supervision evidence; no relevant outstanding returns or unpaid tax unless covered by a payment plan; no HMRC refusal decision; no anti-avoidance sanction or stop notice; no unspent fraud/tax convictions; not insolvent; not suspended/banned); relevant individuals: all officers where 5 or fewer, at least 5 where 6 or more; relevant individuals must not be disqualified as directors. PII is not listed.
• legislation.gov.uk: Prohibition: a tax adviser may not interact with HMRC about a client’s tax affairs unless registered or a Schedule 20 exception applies; definition of interacting.
• legislation.gov.uk: The three registration conditions (compliance/fitness list including director disqualification, insolvency practitioner acting and unspent convictions; AML supervisory registration; nomination of at least five officer relevant individuals for organisations with six or more officers). No insurance condition.
• legislation.gov.uk: Appointed days: first tranche 18 August 2026, second 18 November 2026 (SA/CT account, no ASA), third 18 February 2027 (payroll only), fourth 1 April 2027 (regulated financial services); advisers with an agent services account immediately before 18 August 2026 treated as registered from that date.
• gov.uk: Registration windows by group (18 May–17 Aug 2026; 18 Aug–17 Nov 2026; 18 Nov 2026–17 Feb 2027; 31 Dec 2026–31 Mar 2027); three months from start of window; can keep interacting during window and while application processed; payroll/financial services tranches only where solely those services.
• gov.uk: Statutory exceptions (Schedule 20) and the rule that a business cannot rely on an exception for part of its activity to avoid registration.
• gov.uk: Having applied for AML supervision is not accepted; to remain registered, meet the conditions and act consistently with the HMRC standard for agents.
• gov.uk: Advisers with an agent services account before 18 May 2026 need not submit a new application; subject to sanctions and ongoing conditions from 18 August 2026; HMRC contacts them through the account if it needs more information.
• gov.uk: Suspension (30 days to fix, 60 days for unpaid tax; fixed-term suspension up to 12 months for behaviour below the standard); compliance notice, £5,000 penalties, £10,000 penalty and 12-month ban at 5th penalty within two years, permanent ban; client notification within 30 days or £5,000 per client; publication of details; three-month transition period for applicants awaiting a decision.
• gov.uk: “An agent services account is how tax advisers access HMRC’s online services.”
• gov.uk: HMRC standard for agents: expectations on integrity, professional competence and due care, and professional behaviour. Contains no insurance requirement (text checked 28 Sep 2026).
• assets.publishing.service.gov.uk: 30 November 2021 summary of responses: “The government will therefore not be proceeding with the introduction of a requirement for tax advisers to hold PII at this time”; March 2021 consultation; reasons: compulsory PII on its own would not be an effective mechanism to raise standards nor have a meaningful impact on consumer protection and redress; new, potentially risky advisers in the insurance pool could increase premiums for all advisers.
• tax.org.uk: CIOT confirms the current PII Regulations in force are those effective 1 January 2023.
• assets-eu-01.kc-usercontent.com: CIOT/ATT PII Regulations effective 1 January 2023: members in practice must ensure their firm holds PII (2.1); pro bono, subcontractor (named on policy + subrogation waiver), employee and retired exemptions (3.1–3.4); cover for all civil liability incl. costs in connection with taxation services (4.1b); £1m each and every claim (5.1); under £400,000 fee income the greater of 2.5x and £100,000 (5.2); excess max £30,000 per principal (5.3); six years’ cover after ceasing practice (7.1).
• icaew.com: ICAEW confirms the current PII Regulations took effect on 1 September 2024.
• icaew.com: ICAEW PII Regulations effective 1 September 2024: scope (2.1); £2m single claim and aggregate (3.2); under £800,000 fee income 2.5x with £250,000 minimum (3.3); aggregate excess max the higher of £3,000 or 3% (3.7); run-off at least two years then all reasonable steps for a further four years.
• legislation.gov.uk: Insurance Act 2015 s.3: duty of fair presentation before a contract of insurance is entered into, including disclosure of every material circumstance the insured knows or ought to know.

Frequently asked

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information, not legal or tax advice on your individual circumstances, and it does not guarantee that cover will be available or on what terms.