FCA as AML supervisor for accountants and professional services: what changes and when

What the government decided in October 2025

On 21 October 2025 HM Treasury published its response to the 2023 consultation on AML supervision reform. That consultation set out four models, and the government chose the “Single Professional Services Supervisor” model, with the FCA as that supervisor.

At the moment the UK has 25 AML supervisors: the FCA, HMRC, the Gambling Commission and 22 professional bodies listed in Schedule 1 to the MLRs. Accountants, lawyers and trust or company service providers are split across 23 of them. The government says this fragmentation leads to inconsistent supervision and enforcement. In March 2026 OPBAS said the professional body supervisors were “more effective than at any time since 2018”, but that enforcement still “lacks the teeth to deter firms from falling short”.

The response says the FCA will supervise “all firms currently supervised for AML/CTF matters by a PBS, and all ASPs and TCSPs supervised by HMRC”. That is around 60,000 businesses and sole practitioners. Once the transfer is complete, OPBAS, the FCA unit that oversees the professional bodies, will close.

Who moves to the FCA and who does not

The FCA’s own estimate is about 34,000 accountancy businesses supervised by professional bodies, 7,500 law businesses and 18,000 accountancy businesses and trust or company service providers supervised by HMRC. It says these figures may change.

Your professional body does not disappear. The government expects PBSs to “continue in their important wider regulatory and representative roles”, such as professional standards. Many firms will therefore deal with two bodies: the FCA for AML and their professional body or regulator for everything else.

What has to happen before the FCA takes over

The decision is policy, not yet law. Under regulation 7 of the MLRs, each professional body in Schedule 1 still supervises its members, and HMRC supervises the accountants, tax advisers and trust or company service providers who are not members of one.

Two kinds of legislation are needed:

• Enabling clauses in a Bill. The Financial Services and Markets Bill [HL] lets ministers make regulations requiring the FCA and the professional bodies to cooperate and share information. It also authorises Treasury funding for the FCA’s start-up costs. The Bill completed its House of Lords stages on 15 September 2026 and had its first reading in the Commons the same day. As of 24 October 2026, no date for Commons second reading has been recorded.
• Changes to the MLRs. According to the Bill’s explanatory notes, HM Treasury will make “the majority of changes that this reform requires” through regulations under its existing powers. The FCA register of firms and the new guidance arrangements are among the changes planned this way.

In June 2026 HM Treasury published its response on the FCA’s duties and powers. It confirmed several plans. The FCA will keep a public register of professional services firms, and firms will need to be on it to carry out regulated work. The “fit and proper” test in regulation 58 will be extended to the beneficial owners, officers and managers of accountancy and legal firms, but only after the transfer. Responsibility for AML guidance will move to the FCA, with HM Treasury keeping a veto. Existing legal professional privilege protections stay. All of these still need MLR amendments.

When will the FCA start supervising?

There is still no legal start date. There is, however, an indicative timeline from the FCA and the government.

The FCA published this timeline on 22 September 2026. Lord Stockwood, the minister at HM Treasury and the Department for Business and Trade who is taking the Bill through the Lords, gave the same outline in a letter to Baroness Neville-Rolfe on 2 July 2026. He said the “broad aim” is for the first firms to be supervised “before the end of 2028” and all firms “from mid-2030”. He added that exact timescales depend on risk, operational and other factors. The order in which sectors move has not been published, so do not plan around a specific date for your firm.

The Home Office’s Anti-money laundering and asset recovery strategy 2026 to 2029, published on 15 September 2026, repeats the plan. It says the reform “will reduce the number of AML/CTF supervisors from 25 to 3”, leaving the FCA, HMRC and the Gambling Commission. Its delivery table (action 9) gives two milestones by financial year: legislation laid in 2027/28, “subject to parliamentary time”, and “movement of business to the FCA” in 2028/29. That fits the FCA’s timeline above. It is a government plan, not a new decision and not a legal start date.

What changes and what stays the same

The impact assessment for the Bill says the reform “creates no new requirements for firms to follow”. Any new costs should come from changes in process, such as a new FCA system for paying fees and submitting firm information, rather than from new AML duties.

Fees: what is known so far

• Decided: the government funds the FCA’s setup costs, partly from Economic Crime Levy receipts. The levy is only charged to AML-regulated firms with UK revenue over £10.2 million a year, so small firms do not pay it.
• Decided: once the function is running, the FCA will recover its costs through fees charged to the firms it supervises. It will consult on the fee approach before taking on the role.
• Estimate only: the Treasury impact assessment says the roughly 60,000 firms in scope pay about £30.5m a year in AML fees today. The FCA models its cost at about £35m initially. The assessment rounds the increase to about £5m a year, which would be about £83 a firm if spread evenly. The assessment expects smaller firms to pay lower fees, because FCA fees are usually scaled to the size of the business.
• Unknown: what your professional body will charge for non-AML regulation after the transfer, and whether your total fees will go up or down.

What it means for your type of firm

What to do now

You do not need to contact the FCA, and there is nothing to register for yet. The best preparation is a file that would stand up to inspection by any supervisor:

1. Firm-wide risk assessment. Regulation 18 requires a written assessment of the risks your business faces, kept up to date and provided to your supervisor on request.
2. Policies, controls and procedures. Regulation 19 requires these to be proportionate to your firm’s size and approved by senior management. Check they match what you actually do.
3. Customer due diligence. Make sure every client file shows identity verification, screening and your risk rating (see our CDD guide).
4. Training records. Regulation 24 requires staff training and a written record of it.
5. Your MLRO and reporting. Confirm who your MLRO is and how staff raise concerns.
6. Watch for updates. Read your supervisor’s and the FCA’s updates on registration, fees and onboarding dates.

Our free AML health check takes about two minutes and shows where your file has gaps. Our templates include a firm-wide risk assessment and other documents you can adapt.

How AML Buddy fits in

The change of supervisor does not change how you check clients. With AML Buddy, your client verifies themselves through one secure link: an ID document and selfie check, address match, sanctions and PEP screening and adverse media. You get a timestamped PDF report for the client file, whichever body inspects it. Your firm stays responsible for its own risk decisions. Checks cost £5.40 each including VAT (£4.50 + VAT), with no subscription or monthly minimum, and you get 5 free checks when you sign up. See pricing.