Payroll services to register as Tax Advisers and have AML responsibilities

HMRC are introducing the requirements to register in stages.

From 18th May 2026, HMRC will introduce an online registration system for agent services accounts to register as tax adviserz.

If a payroll service already has an agent services account, they will not need to register again. However, HMRC will contact them through the agent services account when they need more information such as Anti-Money Laundering regulatory registration details.

Who needs to register

Where the provider interacts with HMRC about an employers tax affairs and get paid for it, HMRC will soon consider that to be a tax adviser.

This means that payroll service providers will need to register for an agent services account.

Interaction with HMRC includes:

  • phone, post or email 
  • messages through the GOV.UK website or HMRC app
  • sending returns, claims or other documents

The payroll service legal entity that interacts with HMRC must register. 

Individual employees will not need to register separately, but we’ll need to carry out checks on certain people within your business.

Payroll provider willneed to register even if: 

  • they do not view themselves as a tax adviser, or describe the payroll service as tax advice
  • the business is based outside the UK

You will not need to register for an in-house payroll team, running payroll for their own staff only.

When does payroll need to register

If you only providing third-party payroll services on behalf of clients and do not interact with HMRC in any other way, then registration starts from 18th November 2026

Payroll can also voluntarily use the online service to register from 18th May 2026, even if you’re not required to do so until a later date.

The registration period

Payroll providers have 3 months from 18th November until 17th February 2027 to apply for an agent services account.

They can continue to interact with HMRC on behalf of their clients:

  • during those 3 months
  • And while HMRC consider the registration

Mo Some of the people who work for the payroll services business must also meet the conditions. These people are known as ‘relevant individuals’.

Before you register – AML supervision

Before registering with HMRC, check if you meet HMRC’s conditions to register as a tax adviser

They must provide evidence that the payroll service business is supervised for anti-money laundering.

How to register for AML supervision with HMRC

If the payroll service is not already supervised by a relevant AML regulatory body, then there is an option to be regulated by the HMRC Economic Crime Unit (ECU) for AML.

They can apply to register with HMRC for AML using the online service and be able to pay relevant supervisory fees at the same time.

This is in addition to the separate HMRC tax adviser registration required.

What happens if the payroll service does not register?

If the payroll service needs to register for an agent services account but does not, they will not be able to interact with HMRC on behalf of their clients.

If they do, HMRC may: 

  • issue a formal notice asking them to stop
  • temporarily or permanently ban them from being able to register

If they keep interacting with HMRC after getting a notice to stop, HMRC may charge a penalty.

PAYadvice.UK 17/2/2026

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