Find out if you’re an accountancy service provider who needs to register with HMRC under the money laundering regulations.
Who should register
You may have to register with HMRC if your business operates as an accountancy service provider.
Under money laundering regulations, accountancy service providers are:
- auditors who carry out statutory audit work
- accountants who provide accountancy services to clients
- tax advisers and consultants who provide advice to clients about their tax affairs
- payroll agents that provide accountancy services or tax advice
- customs practitioners, freight forwarders and similar businesses if they provide accountancy or tax services
The services they provide can be recording, reviewing, analysing, calculating and reporting on financial information for other people. This includes:
- professional bookkeeping services
- accounts preparation and signing
- giving a customer specific tax advice
- help with completing and submitting tax returns or duty claims
- advice on whether something is liable to a tax or duty
- advice on the amount of tax or duty that is due
If you provide these services virtually or through an automated service, you’ll still need to perform customer due diligence on your customer.
If you do some but not all these things, and you’re still not sure, you can contact HMRC for guidance.
Who does not need to register
You do not need to register if you:
- are an insolvency practitioner (you’ll be supervised by the Insolvency Service)
- give tax advice or accountancy services on a non-commercial basis, for example, within your own organisation rather than to a third party
- give customers, or link to, basic tax information that would be the same for everyone (such as the basic rate of Income Tax)
Payroll businesses that do not need to register
If you’re a payroll services provider to a third party, you’re not an accountancy service provider for the purposes of the money laundering regulations if you only do any of the following:
- provide software or hardware service support for payroll data processing, as long as you do not analyse or prepare any financial information
- pay invoiced service fees to self-employed people, umbrella companies, partnerships or other corporate service providers
- operate as a body such as an umbrella company or a managed service company and carry out payroll functions for employees who are working on assignments for an end-user client
- provide recruitment or human resources management services and carry out payroll functions as a small part of your main business activity (for example, you might be an employment business that supplies or manages temporary or contract workers)
Customs practitioners that do not need to register
If you’re in business as a customs practitioner, a freight forwarder or similar, you’re not covered by the money laundering regulations if you only provide the following services:
- helping your clients with classifying or valuing exports and imports for customs purposes
- helping clients to comply with customs and other procedures, for example, using simplified declaration procedures or facilities such as warehousing
- helping clients with import or export licensing, and submitting import and export declarations on their behalf
- paying duties, taxes and levies on behalf of importers
Virtual assistants that do not need to register
If you only provide a small amount of accountancy services as a virtual assistant, you may not need to register.
You will not need to register if all the following applies:
- virtual assistant is your main business
- your annual business turnover is less than £30,000
- no more than 5% of your total business turnover applies to accountancy service activities
- the accountancy services you provide support your main business
- there is no other business activity you need to register under money laundering regulations
- your work is reviewed by an accountant or bookkeeper who is registered for money laundering supervision
If you have worked out that you do not need to register, you should contact HMRC providing:
- a declaration of how your business meets each of the criteria
- details of your business
- a contact name
- your business address
- a contact email address
- a contact telephone number
Once you’ve sent the email to us, there’s nothing more you need to do except keep a copy for your business records.
If the business changes in the future, and any of the criteria do not apply, you must apply to register for supervision by HMRC or one of the professional body supervisors of accountancy service providers.
HMRC may contact or visit virtual assistants claiming the concession to check that the qualifying conditions are being met.
Accountancy service providers already registered or supervised elsewhere
If you’re an accountancy service provider, you must register with HMRC unless:
- you’re already supervised for money laundering regulations purposes by a professional body
- all your customers are themselves supervised by HMRC or a professional body
The main supervisory bodies
For money laundering regulations, the main supervisory bodies for accountants, bookkeepers, tax advisers and other financial advisers are the:
- Association of Accounting Technicians
- Association of Chartered Certified Accountants
- Association of International Accountants
- Association of Taxation Technicians
- Chartered Institute of Management Accountants
- Chartered Institute of Taxation
- Financial Conduct Authority
- Institute of Certified Bookkeepers
- Institute of Chartered Accountants in Ireland
- Institute of Chartered Accountants in Scotland
- Institute of Chartered Accountants of England and Wales
- Institute of Financial Accountants
- Institute of Accountants and Bookkeepers
- Law Society
If you’re supervised by one of these bodies, you do not need to register with HMRC.
If all your customers are accountancy service providers or banks
If all your customers are accountancy service providers supervised by HMRC or a professional body, or banks supervised by the Financial Conduct Authority you do not need to register so long as:
- you do not do business directly with the supervised accountancy service providers’ or the banks own customers
- you’re included in the supervised accountancy service providers’ or banks anti-money laundering controls and procedures, suspicious activity reporting, and training programmes
- you have a written contract with each of your customers confirming that every aspect of the relationship between you meets all anti-money laundering requirements
You need to meet all these conditions, otherwise you’ll need to register.
How to register
Apply to register with HMRC using the online service. You’ll be able to pay your fees at the same time.
Find out more about the fees you’ll need to pay for money laundering supervision.
Annual supervision
At the end of each registration period, we’ll send you a notice inviting you to update your registration by paying the annual fee on all your listed premises.
If you do not need your registration to continue, then you should deregister your business.
If you do not pay the correct fee, then HMRC may terminate your registration and remove your business from its anti-money laundering register.
Get more information
HMRC has published guidance for accountancy businesses on how to comply with their obligations under the money laundering regulations and related legislation.
The guidance explains what businesses must do to protect themselves from the risks of money laundering and terrorist financing and how to report suspicious activity.
You can also watch recorded webinars to find out more about money laundering supervision.
