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- 10 Dec 2026 AU Does your privacy policy explain your automated KYC decisions?
- End 2026 EU Is your ID verification ready for EUDI Wallets?
- 1 Jan 2027 US Can your age checks keep up state by state?
- 1 Apr 2027 JP Is your eKYC ready for the IC-chip mandate?
- 10 Jul 2027 EU Is your CDD flow ready for the AMLR?
- 1 Jan 2028 US Are your adviser clients ready for FinCEN’s AML rule?
- 31 Mar 2029 AU Is your initial CDD on the new AUSTRAC model?
- Now AU Tranche 2 is live. Is your AML/CTF program running?
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.
- 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.
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
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.
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.
- 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 - 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 - 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 - 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.
- 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.
- 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
What firms get wrong
Supervision mistakes are usually about the wrong body, the wrong test, or reading an old page.
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.
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 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.
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.
What happens when
- In force
Current HMRC registration fees take effect, per HMRC fee guidance updated 22 December 2025 Source
- In force
SI 2026/621 in force: sterling thresholds across supervised sectors; off-the-shelf company sales become TCSP activity Source
- 2027 (expected)Proposed
FCA operating model review, following expected Government legislation Source
Not yet confirmed. We will update this when the date is set.
- 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.
- 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.
Related guides
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.
Primary sources
Checked 5 Nov 2026. We review this page every 90 days and when the rules change.
- GOV.UK (HMRC), Money Laundering Regulations: who needs to register
- GOV.UK (HMRC), Money Laundering Regulations: registration fees
- GOV.UK (HMRC), Register or renew your money laundering supervision with HMRC
- legislation.gov.uk, MLR 2017 Schedule 1, Professional Bodies
- legislation.gov.uk, SI 2026/621
- FCA, AML supervisory reform
- HM Treasury, AML/CTF Supervision Reform: Duties, Powers, and Accountability Consultation Response (June 2026)
- GOV.UK, Applying to register as a Companies House authorised agent
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.
- 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
- 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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