Finance Bill 2026 leaves conveyancers across the country scrambling to register as ‘tax advisers’

The Finance Bill 2026 is currently passing through the final stages of Parliament and is expected to receive Royal Assent by April 2026.

The Finance Bill, among other things, requires all “tax advisers” to register with HMRC. Even for firms like ours that do not generally advise on tax issues, we fall within HMRC’s very broad definition:

"If you interact with HMRC about someone else’s tax affairs and get paid for it, we consider you to be a tax adviser. This means you’ll need to register for an agent services account".

This means that all firms that submit Stamp Duty Land Tax (SDLT) returns on behalf of their clients, including our firm, must go through mandatory registration as tax advisers.

The Law Society’s position, which we agree with, is that firms that only intend to deal with incidental tax functions, without providing specialist tax advice, should have a specific carve-out within the tax adviser registration scheme. As the scheme currently stands, firms that submit SDLT returns on behalf of their clients are subject to the same level of scrutiny as full-time professional tax advisers.

Nevertheless, our firm will comply with the new requirements and will ensure that we register by the legislative deadline of 18 May 2026, ensuring that there is no change from our clients’ perspective. We will continue to complete SDLT returns on behalf of our clients, where instructed to do so.