Technical Alert (Reminder) – HMRC Tax Adviser Registration – IP Exemption Clarification

IPA Insolvency Practitioner newsletter, August 2026

As mentioned in our ‘Technical Insights’ in March and June 2026, HMRC introduced an online registration system for agent services accounts, which became effective from 18 May 2026. The good news for Insolvency Practitioners (IPs) was that they were exempt from online registration. This alert acts as a reminder for members on the registration system introduced by HMRC.

Key reminders

(1) Registration system – Effective 18 May 2026, HMRC introduced an online registration system for Agent Services Accounts.

(2) Exemption for formal IP appointments – IPs acting in their official capacity are exempt from this registration requirement.

(3) Scope of exemption – The statutory exemption covers interactions where an IP acts pursuant to a legal requirement, including formal appointments and interactions as a Nominee or Supervisor in Voluntary Arrangements (IVAs and CVAs).

Further details

Under updated HMRC guidance (“Check if and when you need to register as a tax adviser with HMRC”), individuals and firms are not required to register for an Agent Services Account if they interact with HMRC on behalf of taxpayers because the law requires it, even if remuneration is received.
Specifically, this exemption applies to:

• Statutory insolvency appointments – all interactions with HMRC carried out in the performance of statutory duties as an IP.
• Voluntary Arrangements – Formal steps and communications taken by an IP when acting as a Nominee or Supervisor in an IVA or CVA.
• General exemptions – In-house payroll administration, intra-group tax affairs, and unremunerated/charitable tax advice.

Guidance

Members can review the HMRC criteria and exemption categories directly on GOV.UK:

HMRC Guidance: Check if and when you need to register as a tax adviser with HMRC