Find out if you're an accountancy service provider who needs to register with HMRC under the money laundering regulations: Money laundering supervision for accountancy service providers - GOV.UK (www.gov.uk)


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.