HMRC AML supervision for accountants and bookkeepers: who must register, what it costs and the 45-day wait

An accountant or bookkeeper who is not supervised by a professional body must register with HMRC for anti-money-laundering supervision. For a sole practitioner with one office that costs £740 in the first year and £400 a year after it. The figures below are from GOV.UK's fee page, read on 1 October 2026.

Who has to register with HMRC

GOV.UK's list of accountancy service providers covers auditors, accountants who provide services to clients, tax advisers, and payroll agents who provide accountancy services or tax advice. The services include professional bookkeeping, accounts preparation, and help with completing and submitting tax returns.

A practice must register with HMRC unless one of two things is true. Either it is already supervised by a professional body, or every one of its customers is itself supervised. GOV.UK names 14 supervisory bodies, among them AAT, ACCA, ATT, CIOT, ICAEW, the Institute of Certified Bookkeepers and the Institute of Financial Accountants. Membership of one of those, with supervision in place, means no HMRC registration.

GOV.UK states the consequence in one line: trading while not registered is a criminal offence and may result in a penalty or prosecution. An accountancy practice may trade while its application is being processed. Only money service businesses and trust or company service providers must wait for confirmation.

There is one narrow exception for virtual assistants. It needs all six conditions on GOV.UK to be met, including annual turnover under £30,000, no more than 5% of turnover from accountancy services, and work that is checked by a registered accountant or bookkeeper. The assistant sends HMRC a declaration by email, and HMRC says it may visit to check.

What it costs

The approval check covers beneficial owners, officers, senior managers and sole practitioners. Officers include partners, directors and the nominated officer. A manager who is not routinely involved in the practice's anti-money-laundering policies is not tested. A practice that also acts as a trust or company service provider comes under the fit and proper test, at £500 for each person tested.

Three example practices, worked from the table:

Two changes after registration have their own prices. A premises added in the first 6 months of the registration year costs the full £400, and one added in the second 6 months costs half, £200. A new partner costs £40 for the approval check, and can start in the role once the application for approval is submitted, but must stop at once if the check is failed.

The reduction for very small practices

A business with turnover under £5,000 can apply for the small business reduction. The detailed section of GOV.UK's page says the practice pays the £300 and the £400 in full, then receives a £500 refund once the application is accepted. That leaves £200, plus the £40 check. The same page says elsewhere that the application fee is "waived" for these businesses; we have used the detailed wording. The claim is made by email after applying, with "Turnover Reduction" in the subject line, and HMRC aims to refund within 30 days of approval.

The order to apply in

1. Write the practice's risk assessment. HMRC asks for one covering money laundering, terrorist financing and proliferation financing.
2. Put policies, controls and procedures in place for the risks found.
3. List every beneficial owner, officer and manager, and every premises where supervised work takes place. HMRC says it may reject an application that lacks any of steps 1 to 3.
4. Apply online with a Government Gateway user ID: a personal one for a sole proprietor, the business's own for a partnership, company or LLP.
5. Pay the fees. HMRC will not look at the application until they are paid. Keep the payment reference, which has 12 digits and 2 letters and starts with X.
6. Wait. HMRC says its review of a new application can take up to 45 days, and longer if it has to ask for information.
7. Only then apply for an agent services account. HMRC rejects that application while supervision is still pending, and without the account a practice cannot sign clients up for MTD for Income Tax.

Every year after

HMRC sends a message to the online account 30 days before the annual declaration and fee are due. There are two stages: submit the declaration, then pay the fee quoting the reference. If either stage is late, the registration is cancelled. Coming back means a new application, with the £300 application fee and the premises fee again. For the sole practitioner above, a lapse turns a £400 year into a £700 one. HMRC issues no paper certificate, so keep a dated copy of the confirmation with the practice's AML file.

What is changing

On 21 October 2025 the government published its decision to move anti-money-laundering supervision of accountancy, legal, and trust and company service providers to the Financial Conduct Authority. The summary we read gives no start date. Until a date is set, a practice is supervised by its professional body or by HMRC, and the fees above apply.

Where this sits in the practice file

Registration is the first item in our AML checklist for accountants and bookkeepers, which covers what supervision then expects, from due diligence to reporting. Supervision is also a condition of registering as an authorised agent with Companies House: its guidance says the agent must already be registered with an AML supervisory body, and that it will reject an application where the name and membership number do not match the supervisor's record. Our guide to Companies House identity verification covers that route.

This is general information, not legal advice. Fees and forms change; check GOV.UK and the dates above before paying.