Tax adviser checks cover strategic control over service delivery

Tax adviser businesses must identify people who exercise significant strategic or managerial control over how their tax advice services are run, including decisions about how services are managed or deliveredGOV. HMRC also clarifies overseas evidence, individuals’ responsibility and registration-window end dates.

Under the statutory test, a relevant individual works for the adviser and plays a significant role in deciding how the whole or a substantial part of its tax adviser activities are managed or organised, or in actually managing or organising themLegislation. HMRC describes a substantial part as a distinct, independent area judged by scale, importance or contribution to the business, excluding minor or supporting functionsGOV. Job titles and routine client-facing work alone do not determine the result.

The officer minimum remains essentialGOV. Where an organisation has fewer than six officers, every officer is included alongside other workers meeting the substantive testGOV. With six or more officers, the organisation identifies everyone meeting that test and, if fewer than five are officers, nominates enough additional officers to reach fiveGOV. Overseas location does not exclude a person exercising substantive control over the UK entity’s tax advice; general network oversight alone is insufficient.

HMRC clarifies that identifying someone as a relevant individual does not make them personally responsible for the business’s compliance or for keeping clients’ tax affairs and payments up to date. Their own minimum standards and cooperation with checks remain relevant. Registration conditions must be met continuously, with checks at registration, periodic reviews and risk-based activity; frequency depends on circumstances and riskGOV. HMRC does not require particular internal governance arrangements solely for registration.

Overseas advisers and overseas relevant individuals may need additional evidence. HMRC’s linked overseas guidance expects evidence requirements to begin in early 2027, with independent notarisation or an equivalent professional’s certification and certified English translations where necessary. Alternative evidence is planned where a requirement cannot be met in the UK manner. HMRC will provide instructions before requesting evidenceGOV; overseas advisers must still register by their applicable deadline using the overseas processGOV.

UK businesses without an Agent Services Account must supply relevant-individual details, including overseas individuals, when registeringGOV. Existing account holders will be contacted in early 2027. Overseas advisers need not provide relevant-individual information until the overseas evidence changes are introducedGOV; businesses should not proactively submit evidence.

The scope guidance treats payment as including business receipts in money’s worth. Statutory assistance covers tax advice, acting or purporting to act as an agent, and assistance with documents likely to inform HMRC’s determination of a client’s tax position. Registration attaches to the legal entityGOV; employees, partners and equivalent office-holders do not register personally for its servicesGOV. The examples of business types remain non-exhaustive. The insolvency-practitioner example now includes overseas practitioners exercising equivalent functions, citing the statutory definitionGOV; the statutory exception concerns interactions to comply with the adviser’s own legal obligation.

HMRC’s revised MTAR10800 timetable ends the first window on 17 August 2026 for advisers without the specified accounts. For Self Assessment or Corporation Tax account holders without an Agent Services Account, it ends on 17 November 2026GOV. For payroll-only advisers without an Agent Services Account, it ends on 17 February 2027GOV. The previous MTAR10800 timetable ended those windows on 18 August 2026, 18 November 2026 and 18 February 2027GOV. The financial-services window still ends on 31 March 2027GOV. Wider services may bring a business within an earlier tranche. Timely applicants can continue client interactions during processing.

The guidance applies Finance Act 2026, sections 224, 226 and 228 and Schedule 20, alongside the Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026GOV.