United Kingdom · AML

HMRC AML supervision: who HMRC supervises and how registration works

Every UK business covered by the Money Laundering Regulations needs an AML supervisor. For accountants without a professional body, trust and company service providers and property agents, that is often HMRC.

In brief
  • HMRC is the AML supervisor for accountancy service providers and trust or company service providers that are not supervised by a professional body or the FCA, and for estate and letting agency businesses, among others.
  • An accountant who is a member of a professional body that supervises it, such as ICAEW, ACCA or AAT, registers with that body and does not also register with HMRC.
  • HMRC charges £400 per premises to register and the same each year for the annual declaration, plus £40 per person for an approval check or £500 per person for a fit and proper test.
  • New HMRC applications can take up to 45 days, and trust or company service providers must not trade until registration is confirmed.
  • The Government has decided the FCA will take over AML supervision of accountancy, legal and TCSP firms; the FCA does not expect to start before autumn 2028.

United Kingdom · AML/CTF · HMRC; professional body supervisors overseen by OPBAS; FCA from a future date · Reviewed 5 Nov 2026

Industries: Accounting, Trust and company services, Real estate, Precious metals and stones

What it is

What it is

The Money Laundering Regulations 2017 require every relevant person to be supervised. A supervisor registers the business, tests the people who run it, inspects how it applies the regulations and can take enforcement action. See Money Laundering Regulations for the underlying duties.

There are two kinds of supervisor for professional firms. Professional body supervisors (PBSs) are the 22 bodies listed in Schedule 1 to the regulations, including the Institute of Chartered Accountants in England and Wales (ICAEW), the Association of Chartered Certified Accountants (ACCA), the Association of Accounting Technicians (AAT) and the Law Society. HMRC is the statutory supervisor for businesses that fall outside a professional body and outside the FCA.

The Office for Professional Body AML Supervision (OPBAS) oversees the professional bodies. That structure is now set to change. In October 2025 the Government announced that the FCA will become the AML supervisor for legal, accountancy and trust and company service providers. HM Treasury published its response on the FCA's duties and powers in June 2026.

Who it applies to

Who it applies to

HMRC lists the sectors it supervises on GOV.UK. For professional services, the test is whether a professional body already supervises you for AML.

  • Accountancy service providers not supervised by a professional body
  • Trust or company service providers not supervised by the FCA or a professional body
  • Estate agency businesses and letting agency businesses
  • High value dealers and art market participants
  • Money service businesses, bill payment service providers and telecommunications, digital and IT payment service providers not supervised by the FCA

If a professional body that acts as a supervisory authority already supervises you, you do not need to register with HMRC.

The obligations

What you have to do

Registration and testing are procedural duties owed to the supervisor. The customer-facing duties are the same whichever body supervises you.

  1. Register with the right supervisor

    Register with your professional body, or with HMRC through its online service using a Government Gateway user ID. HMRC will not review an application until the fees are paid.

    One-off
  2. Have your risk assessment and policies ready first

    HMRC asks for a risk assessment and policies, controls and procedures before you apply, and says it may reject or refuse an application without them.

    One-off, then review
  3. Put your people through the right test

    List every beneficial owner, officer and manager. Accountancy service providers, estate and letting agents, high value dealers and art market participants need an approval check (reg 26). Trust or company service providers and money service businesses need a fit and proper test (reg 58).

    Per person
  4. Apply CDD to every client

    Your supervisor inspects how you identify and verify clients and their beneficial owners. These checks follow the Money Laundering Regulations, not the supervisor.

  5. Screen and risk-rate clients

    Supervisors expect to see PEP checks, enhanced due diligence for higher risk, and a recorded risk rating for each client, in line with your own risk assessment.

  6. Renew every year

    HMRC sends a message 30 days before the due date. Complete the annual declaration and pay the annual fee on time, or HMRC cancels your registration and you must apply again.

    Annual
Commonly misread

What firms get wrong

Supervision mistakes are usually about the wrong body, the wrong test, or reading an old page.

Accountants must register with HMRC as well as their professional body

HMRC guidance says you do not need to register with HMRC if you are already supervised by the FCA or a professional body acting as a supervisory authority.

Approval checks and fit and proper tests are the same thing

The regulation 26 approval check focuses on criminal convictions of beneficial owners, officers and managers. The regulation 58 fit and proper test, used for TCSPs and money service businesses, also looks at integrity, competence and compliance history. HM Treasury plans to apply regulation 58 to accountancy and legal firms once supervision moves to the FCA.

The FCA already supervises accountants for AML

The FCA says nothing changes immediately. Firms should keep following existing AML processes and contact their current supervisor with questions. Its published plan puts the start of a phased transition no earlier than autumn 2028.

Thresholds on HMRC guidance pages are current

Some HMRC guidance pages still quote amounts in euros. Since 30 June 2026 the regulations use sterling, for example £10,000 for high value dealers' cash transactions. Check thresholds against the regulations on legislation.gov.uk.

Key dates

What happens when

  1. In force

    Current HMRC registration fees take effect, per HMRC fee guidance updated 22 December 2025 Source

  2. In force

    SI 2026/621 in force: sterling thresholds across supervised sectors; off-the-shelf company sales become TCSP activity Source

  3. 2027 (expected)Proposed

    FCA operating model review, following expected Government legislation Source

    Not yet confirmed. We will update this when the date is set.

  4. Not yet set (FCA expects autumn 2028 at the earliest)Proposed

    Phased transfer of AML supervision of accountancy, legal and TCSP firms to the FCA begins Source

    Not yet confirmed. We will update this when the date is set.

  5. 2030 (expected)Proposed

    Remaining professional body supervisors move to FCA supervision; OPBAS closes once transition is complete Source

    Not yet confirmed. We will update this when the date is set.

Questions

Questions people ask

Who needs to register with HMRC for AML supervision?

Businesses in the regulated sector with no other supervisor, including accountancy service providers and trust or company service providers not supervised by a professional body or the FCA, estate and letting agents, high value dealers, art market participants and some payment businesses.

Do I register with HMRC or ICAEW, ACCA or AAT?

If you are a member of a professional body that supervises its members for AML, register with that body. If you are not, and you provide accountancy services by way of business, register with HMRC.

How much does HMRC AML registration cost?

HMRC charges £400 per premises when you register and £400 per premises for each annual declaration. Each beneficial owner, officer or manager also needs a £40 approval check or a £500 fit and proper test, depending on your business type. Professional bodies set their own fees.

How long does HMRC AML registration take?

HMRC says new applications can take up to 45 days, longer if it needs more information. Trust or company service providers and money service businesses must not trade until registration is confirmed; other businesses can trade while the application is processed.

What does an AML supervisor check when it inspects a firm?

How the firm meets the Money Laundering Regulations: its risk assessment, policies, training, customer due diligence, enhanced checks and records. See the AML customer due diligence checklist.

Is HMRC still going to supervise accountants?

For now, yes. The Government has decided the FCA will take over AML supervision of accountancy, legal and TCSP firms, with changes made through the Financial Services and Markets Bill and amendments to the regulations. No start date is fixed.

Do I need AML supervision to become an ACSP?

Yes. Companies House only registers a business as an Authorised Corporate Service Provider if it is registered with a UK AML supervisory body. See Companies House identity verification.

Where StackGo fits

Where StackGo fits

Registration, testing and renewal are between your firm and its supervisor. IdentityCheck plays no part in them. It is one way to run the client checks a supervisor inspects and keep the evidence together. Other approaches exist, including doing this manually.

What IdentityCheck covers today
  • Identity verification with a photo of a government ID document plus a live selfie with liveness, covering 12,500 document types from 230+ countries and territories
  • Onboarding forms, including multi-entity forms for each person and entity on a structure
  • PEP, sanctions and adverse media screening, with ongoing monitoring of screened clients
  • Risk assessment forms with scoring and enhanced due diligence steps
  • Two-way integrations with Xero Practice Manager, Xero, Karbon and HubSpot; by default no personal details are written back, only a link to the result plus the outcome and status
What it does not do
  • It does not register your firm with HMRC or a professional body, or file annual declarations or any HMRC return
  • It does not run approval checks or fit and proper tests on your own staff for your supervisor
  • It does not lodge suspicious activity reports or do transaction monitoring
  • It does not give legal advice

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