Tax Advisers – Mandatory Registration with HMRC
From 18 May 2026, HMRC are introducing a new requirement for ‘tax advisers’ to register and meet ‘minimum standards’. HMRC state that the purpose of this requirement is to raise standards in the tax advice market and to support economic growth. The requirements are based on activities, not professional title.
A tax adviser is defined in the legislation as an organisation or individual who, in the course of a business carried on by them, assists other persons with their tax affairs.
Assisting with tax affairs is broadly defined to include:
- Providing advice in relation to tax
- Acting or purporting to act as an agent on behalf of the other person in relation to tax
- Providing assistance with any document that is likely to be relied on by HMRC to determine the other person’s tax position.
Interacting with HMRC includes:
- Contacting HMRC by telephone, post or email
- Sending a message to HMRC through a website or online portal
- Filing returns, claims, notices or other documents with HMRC
- Communicating with HMRC in any other way
For notaries, this means that there is no automatic exemption. The key issues are the nature of the work performed.
Notaries who communicate with HMRC on behalf of their clients, help prepare or submit tax-related documents, or provide advice that influences a client’s tax position will be required to register. Even if tax is only a small part of a broader service, the requirement to register can still apply.
The legislation on registration is included in Part 7, Schedule 19 and Schedule 20 of Finance Bill 2025-26, published here.
HMRC published the following guidance on 17 February 2026: