HMRC has updated its guidance requiring non-UK agents to provide anti-money laundering supervisory details when applying for an agent services account, with ongoing compliance conditions now in effect.
HMRC has updated its guidance on how agents based outside of the UK can apply for an agent services account (ASA), requiring them to provide their anti-money laundering (AML) supervisory details when applying for approval, or if they do not need to register with an AML supervisory body, they should answer 'No' to the relevant question and upload a document explaining why registration is not required alongside their proof of trading address.
The clarification follows the implementation of broader tax adviser registration requirements and forms part of HMRC's drive to strengthen compliance across its agent population.
Existing Agent Services Account holders became subject to the ongoing registration conditions and sanctions framework from 18 August 2026, meaning that ongoing compliance requirements now apply. This marks a critical enforcement milestone for HMRC, which has been progressively tightening standards across its agent network.
Overseas agents: What you need to know
For UK accountancy firms that work with or refer clients to overseas-based agents—whether in EU jurisdictions, the Middle East, or elsewhere—HMRC's updated guidance has practical implications.
The updated guidance requires agents based outside the UK to provide their AML supervisory details when applying to HMRC for approval. This reflects international anti-money laundering standards and ensures that any agent interacting with HMRC on behalf of UK taxpayers meets equivalent compliance bars to their UK counterparts.
Importantly, if an agent does not need to register with an AML supervisory body in their country, they should answer 'No' to the relevant question and upload a document explaining why registration is not required alongside their proof of trading address. This provides clarity for agents operating in jurisdictions with different regulatory frameworks—for instance, some countries impose AML supervision on banks and financial institutions but not on professional advisers. Agents in such regimes will now need to evidence that their jurisdiction does not impose such requirements, rather than being unable to complete the ASA application form.
Practical compliance implications
Where HMRC requires further information to determine whether ongoing registration conditions are met, it will contact the tax adviser through their ASA. Firms should ensure that any overseas agents they work with have updated their ASA details on HMRC's systems and are prepared to respond promptly to any information requests. Delay or failure to provide the required documentation could result in suspension or cancellation of the ASA, disrupting your clients' tax administration.
Businesses that have relied on HMRC's published guidance in good faith should be treated as compliant if HMRC later clarifies that registration is required. This safe harbour provides some reassurance, though firms should not rely on it as a substitute for proactive compliance.
Looking ahead
The tightening of ASA requirements reflects a broader pattern of HMRC enforcement and the government's commitment to professional standards. As accountancy firms increasingly operate in global markets, maintaining compliant relationships with overseas agents—and understanding HMRC's expectations around those relationships—is a key risk management function. If your firm engages overseas agents, now is the time to review their ASA status, AML supervisory position, and documentation on file with HMRC.
The 28 October 2026 Budget is expected to bring announcements on business taxation and compliance investment; further clarifications on agent supervision may be forthcoming.