HMRC AML fines tracker: penalties by sector (updated October 2026)

Headline numbers: April to September 2025

Penalties by sector, April to September 2025

These are the named penalties only. HMRC gives no sector split for anonymised or minor penalties.

Penalties by sector in earlier periods

HMRC’s periods are uneven, so compare the shape rather than the raw totals.

The trend since 2021

The table below covers every list currently on GOV.UK. “Total” adds HMRC’s anonymised and minor penalty totals to the named penalties.

Three things stand out:

• Volume rose sharply from 2021 to late 2023, then settled. Named penalties went from about 15 a month in late 2021 to about 92 a month in October to December 2023. Since 2024 the rate has been between 56 and 61 a month.
• Big totals are driven by a few big cases. The January to March 2022 and July to December 2022 totals look high because of five penalties on money service businesses worth £2.9 million between them. Without those, both periods would look like the others.
• Estate agents are consistently the largest group. Across all lists since April 2021, estate agency businesses account for 1,400 of 2,527 named penalties (55%) and £8.7 million of £17.7 million (49%). Accountancy service providers account for 788 penalties and £3.5 million.

What the fines were for

HMRC gives the regulation breached and a short description for each named penalty. We grouped them into categories; one penalty can fall into more than one.

The pattern is clear. Most published penalties are not about poor checks on customers. They are about firms that carried on regulated business without registering with HMRC first. HMRC’s own guidance says an estate agency business must register “before carrying on any activity” as an estate agency business.

The penalties for weak systems are rarer but much larger. Across all lists, 54 named penalties involved risk assessment, policies, CDD, training or record keeping. They total £3.8 million, about 21% of all named penalties by value.

The largest penalties

We show the sector, amount and reason only.

April to September 2025

Largest on any list since April 2021

The largest estate agency penalty on the current lists is £92,267 (April to June 2022), for failing to register on time. Penalties of £52,000 on estate agency businesses appear in several periods.

How this compares with HMRC’s annual figures

HM Treasury’s supervision report counts HMRC fines a different way, by reporting year and from HMRC’s annual return, so its totals do not match the GOV.UK lists. It gives these figures for HMRC:

The same report says HMRC supervised 36,782 businesses in 2024-25, including 17,382 estate agency businesses, 2,335 letting agency businesses and 16,251 accountancy service providers. Of the businesses HMRC assessed with an outcome in the same year, 19% were compliant, 21% generally compliant and 60% non-compliant. HMRC also cancelled or suspended 59 registrations and secured 6 criminal convictions under the MLRs.

What estate agents should take from it

• Registration is the first test. Almost every estate agency penalty on the lists is for trading before registering. If you start a new company, add a branch under a different entity or take on regulated work such as lettings or commercial sales, check that each business is registered. See our guide to AML requirements for UK estate agents.
• Tell HMRC about changes. Failure to notify a material change is the second most common reason in the latest list.
• Systems penalties are rare but costly. If HMRC inspects you, it will look at your risk assessment, policies, training records and customer due diligence files, for buyers as well as sellers.
• There is a charge on top. HMRC adds a sanction administration charge of up to £2,000 to its financial penalties.

What letting agents should take from it

HMRC appears to list most agents that do lettings under “estate agency business”, so the data cannot separate them. Only two named penalties are labelled as letting agency businesses. What matters is the rule: the MLRs cover letting agents for tenancies with a monthly rent of £10,000 or more (the threshold was converted from 10,000 euros by SI 2026/621 from 30 June 2026). If you handle lettings at that level, HMRC’s guidance is that you must register before carrying on that business. Our AML guide for letting agents covers what is in scope.

What accountants and bookkeepers should take from it

Accountancy service providers supervised by HMRC are the second largest group, with 204 named penalties worth £1,034,136 in the 12 months to September 2025. 191 of those were for failing to register on time. If you provide accountancy services and are not supervised by a professional body, check that you are registered with HMRC before you take on clients. See AML for accountants.

If you are tightening up your checks, AML Buddy runs ID, sanctions, PEP and adverse media checks with a timestamped report for each client, priced per check (see pricing).

Methodology and caveats

We downloaded every “Businesses that received a penalty notice” table on HMRC’s lists for 2021-22 to 2025-26, as they were online on 23 October 2026. We added up the named penalties by the supervised sector HMRC shows next to each business, and added HMRC’s own totals for anonymised and minor penalties. We cross-checked every period total with a second, independent count. The aggregate data file is available on request.

Please bear in mind:

• Periods are uneven (one to nine months), so per-month rates are the fairer comparison.
• HMRC amends the lists. Entries are removed, anonymised or corrected after publication, so totals can differ from figures reported at the time. Trade press reported 369 penalties totalling £1,881,237 for April to September 2025, with 170 estate agency penalties (£835,842) and 134 accountancy penalties (£513,930). The current list gives 369 penalties totalling £1,853,737. Our sector figures cover named penalties only.
• Sectors are as labelled by HMRC. One penalty listing two sectors is counted under the first. Three penalties in April to September 2023 show no sector.
• Reason categories are ours, based on the regulation numbers and HMRC’s description.
• Published amounts are not final outcomes. Some penalties are under appeal. HMRC does not say whether published amounts include the sanction administration charge.
• Older lists are gone. HMRC removed lists before April 2021 on 10 September 2026, so they are not included. Penalties under the 2007 regulations are excluded.