Introduction - HMRC Changes for Tax Agents
HM Revenue & Customs (HMRC) has recently introduced significant changes in how it works with tax agents – the professional advisers (such as accountants or tax consultants) who handle tax affairs on behalf of clients1. These changes are aimed at raising standards in the tax advice market, protecting taxpayers from poor-quality advice, and improving compliance with tax laws. Three key initiatives stand out: a new Agent Educational Model to support and supervise tax agents, a forthcoming mandatory registration requirement for all tax advisers, and the creation of an HMRC Expert Advisory Panel to guide policy in specialised areas. This blog post will explain each of these changes – their goals, how they work, and what impact they are expected to have on tax agents and the wider public.
HMRC’s New
Agent Educational Model (AEM)
One of the latest initiatives is HMRC’s Agent Educational Model (AEM), a programme designed to collaborate with certain tax agents to improve the accuracy and quality of the work they do for clients. Launched as a pilot in January 2024, initially focusing on agents who advise on Research and Development (R&D) tax relief claims, the AEM pairs HMRC staff with tax agents to provide education and guidance 2. In this model, if HMRC identifies an agent who has submitted multiple tax claims with similar risk factors or errors, that agent may be assigned an HMRC “Agent Relationship Manager”. This HMRC manager works closely with the agent to review their processes, highlight common mistakes, and ensure the agent understands how to get claims right 2. The goal is that, through this hands-on support, the agent can file future claims with greater confidence and accuracy, having provided all necessary information to satisfy HMRC’s requirements 3.
It’s important to note what the AEM is not. Participation in the Agent Educational Model does not confer any special status or accreditation on an agent, nor does it mean HMRC will give their clients preferential treatment 4. It is simply a support mechanism to raise standards. Indeed, HMRC has made clear that normal compliance checks still apply to all claims, and agents who choose not to engage with the educational programme may face further action if they continue to submit questionable claims 5. In other words, the AEM is a cooperative approach – HMRC offering extra help to agents to get things right – backed by the expectation that agents either improve or face the usual enforcement measures.
Intended impact. By investing in agent education, HMRC hopes to prevent errors or abuse before they occur, rather than only reacting afterward. For example, HMRC notes that an agent who was inclined to submit an ineligible R&D claim could, through the AEM, be guided to correct course before filing, resulting in “fewer ineligible claims being made.” 6 In the long run, this should benefit everyone: clients avoid the trouble of having claims rejected or reversed, agents build a reputation for accurate work, and the tax system as a whole sees higher compliance. The Agent Educational Model reflects HMRC’s broader strategy of supporting the tax agent community with information and tools (like webinars, updates, and toolkits) so that “good tax agents” can more easily help taxpayers meet their obligations 7. It’s a new collaborative approach, starting in the high-risk area of R&D tax relief, that could be expanded to other areas if successful in improving agent performance.
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Mandatory
Registration for All Tax Agents
Another major change on the horizon is a new requirement for all tax advisers to register with HMRC and meet minimum standards. Historically, different HMRC services had separate registration processes for agents, and some advisers (especially those not affiliated with professional bodies) could interact with HMRC without any unified oversight. This patchwork system created gaps in HMRC’s ability to ensure every tax adviser is qualified and adhering to basic standards, and it imposed unnecessary paperwork when agents had to sign up multiple times for different tax services 8 9. After consulting with stakeholders in late 2024, the government found “strong support” for making registration mandatory across the board, as a way to improve the security of tax services and deter unscrupulous actors who might otherwise operate under the radar 10.
Starting 1 April 2026, all individuals or firms who act as tax agents must be registered with HMRC in order to represent clients. This will apply to both UK-based and overseas tax advisers who deal with HMRC on behalf of UK taxpayers 11. In preparation for this, HMRC is overhauling its systems – backed by a significant investment to create a modern, streamlined agent registration service 10. The aim is to have a single digital route where an adviser can register once and gain authorisation for all the HMRC services they need, replacing the old siloed registrations (many of which used to involve paper forms and long wait times) 9. There will be at least a three-month transition period leading up to April 2026 to give existing agents time to sign up under the new system 12, and HMRC will be communicating details in advance so that everyone is aware of the changes.
What does registration entail? In practice, registering with HMRC will likely require the agent to provide identifying information and confirm they meet certain conditions – for example, that they are properly supervised under anti-money-laundering (AML) regulations (a legal requirement for tax advisers) and that they agree to follow HMRC’s Standard for Agents (a code of conduct for tax agents). HMRC anticipates agents will need to renew or affirm their registration annually, including confirming their continued AML supervision status 13. For most reputable tax agents, these steps won’t be difficult – the vast majority already belong to professional bodies or have AML supervision. However, for those fringe operators who “cannot lawfully act as a tax adviser” or who consistently fail to meet basic standards, the mandatory registration will either push them to improve or push them out 14. Under the new rules, any tax adviser who does not meet HMRC’s minimum standards or tries to avoid the registration requirement can be suspended from acting on clients’ behalf, and HMRC may impose further sanctions if necessary 15. This ensures that taxpayers won’t unknowingly be using unqualified or disreputable agents: if an agent isn’t registered (or loses their registered status), they simply won’t be permitted to deal with HMRC for clients.
Why require registration? The official rationale is that a single mandatory registration system will raise the overall quality of tax advice and make the tax system safer and more efficient for everyone. It gives HMRC better oversight of who is acting as an agent and the power to quickly identify those who fall short of the standards. It also protects taxpayers by building a sort of trusted intermediary system – in the future, when you hire a tax adviser, you can have confidence that they have met basic requirements. From the perspective of compliant tax agents, the change is largely positive as well. Legitimate advisers will have a simpler one-stop process to prove their credentials and gain access to HMRC systems, replacing the old multiple registrations 9. And by weeding out unqualified or unethical advisers, the mandatory registration should enhance the reputation of the tax profession as a whole. HMRC has stressed that ordinary taxpayers should not experience any disruption from this measure – your interactions with HMRC remain the same, except that behind the scenes your agent will have a verified status. The only scenario where a taxpayer might notice a change is if their current adviser fails to register or is found not up to standard, in which case that adviser will no longer be allowed to act and the taxpayer would need to seek a different (registered) adviser 16. Overall, this change (due in 2026) is about boosting trust and competence in the system by making sure every tax agent is known, accountable, and meets minimum professional criteria.
HMRC’s Expert
Advisory Panel for R&D Tax Relief
To complement its internal efforts and regulatory changes, HMRC is also seeking outside expertise through a newly created Expert Advisory Panel. Announced in the Spring Budget 2024 as part of a “Corporate Tax Roadmap” initiative, this panel is being set up specifically to advise on the R&D tax relief regime 17. The impetus for this came from the recognition that R&D tax relief which lets companies claim tax relief/credits for research and development involves highly technical judgments about science and technology. By bringing in external experts at the forefront of R&D, HMRC aims to “ensure that R&D tax reliefs continue to support the UK’s most innovative businesses.” 17 In other words, the panel’s job is to help HMRC strike the right balance: make the reliefs accessible and clear for genuine R&D activity, while preventing abuse or mistaken claims.
Who is on the panel? HMRC is in the process of appointing six independent advisors to serve on this Expert Advisory Panel 18. These individuals are being drawn from cutting-edge industries and disciplines – specifically, HMRC has sought experts in Advanced Manufacturing, Technological Development (with at least one specialist in Artificial Intelligence), and Life Sciences 18. The idea is to have a diverse range of technical knowledge represented, so that between them, the panel members understand the kinds of innovation happening in key growth sectors of the economy. All members are independent of HMRC (industry professionals or academics, not government employees) and will contribute their time on a part-time advisory basis. By June 2025, recruitment for these roles was underway 19 20, with HMRC looking for people who not only have deep expertise in their field, but can also explain complex scientific or technological concepts in layman’s terms – a crucial skill for translating R&D concepts into tax guidance.
What does the Expert Advisory Panel do? According to HMRC, the panel will support the tax authority in several important ways:
Provide insight into cutting-edge R&D
The panel will help HMRC stay up-to-date on emerging technologies and research frontiers, enhancing HMRC’s understanding of innovation across sectors. This includes advising on how to assess whether a project truly seeks a scientific/technological advance (a key criterion for R&D relief) by sharing how experts in the field make such judgments 21. In short, the panel acts as HMRC’s window into the fast-moving world of science and tech, ensuring tax rules keep pace with real-world innovation.
Offer sector-specific feedback
The panel will serve as a forum to discuss issues or challenges specific to different industries in the context of R&D tax relief. It will provide HMRC with feedback from the perspective of various sectors, helping identify any aspects of the relief’s administration that might be hindering genuine R&D in that sector or, conversely, being misused 22. This direct line to industry viewpoints can inform HMRC if, for example, guidance in one sector needs clarification or if a particular type of claim is commonly causing confusion.
Improve and “challenge” HMRC’s guidance
One explicit role of the panel is to critically review HMRC’s R&D guidance and other materials to make sure they are clear, accurate, and fit for purpose. The experts are expected to “challenge guidance to ensure it is clear, targeted, and supportive” of innovative companies, and to feed into HMRC’s ongoing updates of manuals and guidelines so that these stay relevant as technology evolves 23. By having external specialists scrutinise the wording and examples in guidance, HMRC hopes to eliminate ambiguities and better communicate what qualifies for relief, thus improving compliance and ease of use.
Enhance HMRC’s communications and foresight
The panel will act as a “critical friend” for HMRC’s outreach and compliance efforts 24. This means the experts might review draft webinar content, template letters, or educational materials that HMRC plans to send to companies and agents, to ensure the messaging is technically sound and effectively delivered. Panel members will also help HMRC with horizon scanning – that is, informing them about emerging trends and innovations (for example, a new field of AI research) that could lead to new types of R&D tax relief claims in the future 25. This forward-looking advice allows HMRC to prepare in advance, possibly updating guidance or policy before new claims arrive.
Through these activities, the Expert Advisory Panel is expected to influence HMRC’s policy and service delivery in the R&D sphere. The panel does not make the rules – HMRC and the government remain the decision-makers – but its expert input will heavily inform how rules are interpreted and applied. For instance, if the panel suggests a clearer definition of what counts as a “scientific uncertainty” in a research project, HMRC might incorporate that into its manuals or even propose legislative tweaks. Likewise, if the panel highlights that companies in a certain cutting-edge industry are struggling to claim relief due to outdated guidance, HMRC can adjust its guidance or provide additional support for that sector. Ultimately, this collaboration should lead to clearer guidance for claimants and more effective oversight by HMRC, as the government itself has noted 26. By better understanding the industries it serves and communicates with, HMRC can administer R&D incentives in a way that encourages genuine innovation while filtering out erroneous or fraudulent claims.
Contact us to discuss how the merged R&D scheme and the enhanced R&D-intensive SME relief could impact your business. With expert guidance, you can confidently navigate the new R&D tax landscape and continue to claim with confidence and certainty.
Conclusion
These three initiatives – the Agent Educational Model, mandatory agent registration, and the Expert Advisory Panel – represent a multifaceted push by HMRC to modernise and reinforce the tax system’s supporting framework. For tax agents and advisers, the message is clear: the bar is being raised. HMRC is offering more support and communication (through programmes like AEM and the expert panel’s guidance), but also demanding more accountability (through required registration and standards). Agents who are committed to professionalism should welcome these changes, as they level the playing field by cracking down on dubious operators and provide new resources to help agents do their jobs better. For taxpayers and businesses, these changes promise a safer and more transparent environment. You should be able to trust that your tax adviser is registered and playing by the rules, that HMRC is actively working with experts to keep guidance up-to-date, and that if mistakes or aggressive claims occur, there are mechanisms in place (like AEM) to correct course early. In summary, HMRC’s recent moves are about building a stronger partnership between the tax authority and the agent community, with the ultimate aim of making tax compliance easier, fairer, and more dependable for all.
HMRC Changes for Tax Agents Sources: Official HMRC and UK government publications. All information and quotes are drawn from HMRC policy papers, consultations, and official announcements on GOV.UK 27 10 28, ensuring an accurate reflection of the latest government policy changes affecting tax agents.