Do solicitors and conveyancers need to register as tax advisers?
08 May 2026
New HMRC rules coming into effect from 18 May 2026 mean that many solicitors and conveyancers will now be considered ‘tax advisers’ and will need to register for an Agent Services Account (ASA).
Under HMRC’s definition, anyone who is paid to interact with HMRC about someone else’s tax affairs is classed as a tax adviser. Interaction with HMRC includes contact by phone, email or post, messages through the GOV.UK website or HMRC app or sending returns, claims or other documents.
This brings a wide range of legal professionals into scope, including conveyancers who submit Stamp Duty Land Tax (SDLT) returns, private client solicitors dealing with inheritance tax, and family law solicitors who communicate with HMRC on behalf of clients.
According to The Law Society, “If your client is buying with a mortgage and you are acting for the buyer/borrower as well as the lender, you are likely to be ‘interacting’ with HMRC.”
The changes may catch some firms out, but failing to register in time could result in being prevented from dealing with HMRC altogether, with serious consequences for ongoing client service.
Who needs to register for an Agent Services Account?
The legal entity, i.e. the company, LLP or partnership needs to register. Sole traders who meet the definition of a tax adviser also need to register. You need to register even if providing tax advice isn’t your main business function or if your business is based outside the UK.
You do not need to register if you only deal with the tax affairs of your own company or group, or if you provide tax advice free of charge (e.g. to friends and family.)
If you are not sure whether you need to register you can check on the GOV.UK website.
When is the Agent Services Account registration deadline?
Registration opens from 18 May 2026 and firms have three months from then to register to apply for an Agent Services Account.
What happens if a firm misses the deadline to register for an Agent Services Account?
If you haven’t registered within three months of the registration opening (i.e. by 18 August 2026), you can be served with a compliance notice. This means you would no longer be able to interact with HMRC on behalf of your clients.
In addition, HMRC may suspend a firm’s registration for up to 12 months if they consider the tax adviser has behaved in a manner which has fallen below the standards that might be reasonably expected.
HMRC can apply financial penalties if a firm attempts to interact with HMRC without being registered or while its registration is suspended.
My firm already has an Agent Services Account. Do I need to do anything?
If you already have an Agent Services Account, HMRC will contact you via your ASA to confirm you meet the registration conditions or to ask for further information. You don’t need to register again.
Do I need to register for an Agent Services Account if my firm already has a Self Assessment or Corporation Tax agent account?
Yes. If your firm already has a Self Assessment or Corporation Tax agent account, you still need to register for an ASA. In these circumstances registration is required within three months from 18 August 2026.
How does the Agent Services Account registration process work?
As part of the registration process, the firm will need to provide their name and address, along with evidence that the business is supervised for anti-money laundering purposes (e.g. by the Solicitors Regulation Authority).
You will also need to provide the names of at least five ‘relevant individuals’. A relevant individual is anyone who makes decisions about or manages the firm’s tax adviser activities.
Your firm must also not:
- Have any relevant outstanding tax returns or unpaid tax (unless covered by a payment plan)
- Be subject to a decision by HMRC refusing to deal with you
- Be subject to an anti-avoidance sanction or stop notice
- Have any unspent convictions for fraud or tax offences
- Be formally insolvent
- Be suspended or permanently banned from registering with HMRC
Relevant individuals must not be disqualified from acting as a director.
Further advice and guidance
If you need further support, please get in touch with one of our solicitor and conveyancer accounting specialists.
- Corby: 01536 461900
- Peterborough: 01733 397300
- Northampton: 01604 654254