HMRC AML supervision: registration, fees and inspections

Which businesses HMRC supervises for AML

HMRC counts 9 business sectors that it supervises under regulation 7 of the MLRs, but only where the FCA or a professional body supervisor (PBS) does not already supervise the business. For most small firms that means estate agents, letting agents and accountancy service providers that do not belong to a professional body supervisor.

The 9 sectors are:

• estate agency businesses (EAB) and letting agency businesses (LAB);
• accountancy service providers: auditors, external accountants and tax advisers with no PBS;
• trust or company service providers not supervised by the FCA or a PBS;
• high value dealers (HVD), art market participants (AMP) and money service businesses not supervised by the FCA;
• bill payment service providers (BPSP) and telecoms, digital and IT payment service providers (TDITPSP).

If you are a member of a professional body such as an accountancy institute, that body may be your supervisor instead. Not sure? Use our free AML supervisor checker to see who supervises a firm like yours.

When you must register

You must apply to HMRC before you start trading in a supervised sector. Estate and letting agents, ASPs, HVDs, AMPs, BPSPs and TDITPSPs may trade while HMRC decides their application, once they have applied (including the approval checks on their BOOMs). MSBs and TCSPs may not trade until HMRC approves them (HMRC guidance AMLG1500). HMRC will not review an application until the fees are paid.

Trading without registration is a criminal offence. HMRC can issue a penalty or prosecute, and its guidance warns that a court may treat the turnover from regulated activity in that period as the proceeds of crime.

How to register with HMRC

To register with HMRC for AML supervision, prepare your risk assessment, policies and the details of every beneficial owner, officer and manager (BOOM) and every premises, then apply through HMRC’s online money laundering supervision service. HMRC can take up to 45 days to decide.

Before you apply, HMRC expects you to have:

1. A written money laundering, terrorist financing and proliferation financing risk assessment. Our guide to client risk assessment for small firms covers the client side.
2. Written policies, controls and procedures (PCPs). You can start from our free AML templates.
3. The names and details of all BOOMs.
4. A list of all your premises.

HMRC says it “may reject or refuse” an application that is not ready. Under MLR reg 57 it can ask for your nominated officer’s details, your risk assessment and how you meet your obligations, and it can require further information, to be provided within 21 days.

Apply through the HMRC online service with a Government Gateway user ID (HMRC’s manual also mentions GOV.UK One Login). Sole traders can use a personal ID; other businesses use the business’s ID. HMRC sends notices to your online account and they count as served, so check it regularly. You will not get a paper certificate.

HMRC AML supervision fees in 2026

HMRC AML supervision fees changed on 1 December 2025. A new business pays a £300 application fee, £400 for each premises (then £400 a year) and £40 or £500 for each person HMRC must check. HMRC sets these fees under MLR reg 102.

A premises added in the second half of your registration year costs half. There is no refund when you remove a premises. Work out your own total with our HMRC AML fees calculator.

Approval checks and the fit and proper test

For the £40 approval check (EABs, LABs, ASPs, HVDs and AMPs), each BOOM must declare any unspent conviction for a relevant offence (listed in Schedule 3 to the MLRs) in any country, and HMRC checks its own and police records. MSBs and TCSPs face the fuller £500 fit and proper test, which also looks at compliance history, skills, experience and probity, including tax affairs.

HMRC guidance expects reasonable care, including at least a basic DBS check (or equivalent) and a signed declaration for officers and managers. A new BOOM cannot act until you have told HMRC and paid the fee. A fit and proper approval does not transfer between businesses.

Your annual declaration and fee

Each year you submit an annual declaration, even if nothing has changed, and then pay the premises fee. HMRC sends an online message 30 days before it is due. If you miss either step, HMRC cancels your registration and you must re-apply and pay the £300 application fee again.

Submitting the declaration gives you a 14-character payment reference starting with X; quote it when you pay. You can pay online by bank account or debit or corporate credit card (not a personal credit card), or by bank transfer. Add the renewal to your calendar alongside the other dates in our AML deadlines calendar.

Changes you must report to HMRC

Tell HMRC about material changes within 30 days (MLR reg 57(4)), and about a new nominated officer or compliance officer within 14 days. Examples include new BOOMs, a new sector or branch, a new operating model or agents, and changes to bank account or addresses.

If you need to appoint or replace your nominated officer, our guide to the MLRO and nominated officer role explains what the job involves.

How HMRC decides who to inspect

HMRC uses a risk-based approach under MLR reg 46. It decides how often and how closely to supervise a business from its risk profile, informed by HMRC’s own sector risk assessments. Checks range from face-to-face visits to desk-based and phone checks, and include pre-registration interventions.

HMRC also reviews each business’s own risk assessment and PCPs, so a document that matches how your firm actually works is your best preparation.

What happens in an HMRC AML inspection

An HMRC AML inspection usually starts with a phone call to agree a date. HMRC’s handbook for its officers says they should normally give at least 7 days’ notice and confirm the visit in writing. That is internal guidance, not a legal right: HMRC can also visit unannounced, and the officer will identify themselves and give a reason.

Before a visit, HMRC usually asks for your written risk assessment and PCPs, plus records for a sample period set out in the confirmation letter. On the day, the officer will:

• check your registration details;
• check approvals (or fit and proper tests) for your BOOMs;
• review how you assess client risk;
• review your PCPs and staff training, and ask you to explain them.

The officer may ask for client ID evidence, training records, internal or external audit reports, bank statements, a senior manager’s job description, and records of suspicious transactions and suspicious activity reports (SARs). HMRC says SARs are not used for tax purposes. A visit usually takes less than a day unless the business is large or complex.

HMRC also has formal powers: it can require information and documents by written notice (reg 66) and enter premises without a warrant on reasonable grounds (reg 69). For a step-by-step preparation list, read how to prepare for an HMRC AML inspection. Estate agents can also use our HMRC AML requirements guide for estate agents.

Penalties for breaking the MLRs

HMRC can impose civil penalties with no upper limit (reg 76) and adds a sanctions administration charge on top. Since 1 December 2025 that charge is £2,000 for most breaches (it was £1,500) and also applies to suspensions, cancellations, censures and prohibitions. Breaching the MLRs can also be a criminal offence carrying up to 2 years in prison and a fine (reg 86).

HMRC reduces penalties for unprompted disclosure (email MLRCIT@hmrc.gov.uk) and for cooperation. You can ask for a review by a different officer and then appeal to a tribunal.

HMRC publishes the names of businesses it penalises. Its latest list, covering April to September 2025 and published on 29 January 2026, records 369 penalties totalling £1,853,737. Estate agency businesses received 160 of the 334 named penalties. See who was fined, and why, in our HMRC AML fines tracker.

What changes when the FCA takes over

Only HMRC-supervised accountancy service providers and trust or company service providers will move to FCA supervision. The FCA expects to start no earlier than autumn 2028 and finish around 2030; there is no legal start date yet. Estate agents, letting agents, HVDs, AMPs and MSBs stay with HMRC.

The FCA says around 18,000 HMRC-supervised ASPs and TCSPs are affected and that they do not need to do anything now. Our guide to the FCA as single AML supervisor covers the timeline. Accountants can see what applies today on our AML for accountants page.

How to contact HMRC about AML supervision

For questions about registration, payment references or voluntary disclosures, email MLRCIT@hmrc.gov.uk. Use AMLS.Fees@hmrc.gov.uk only to claim the turnover reduction. To report an unregistered business, use HMRC’s “Report tax fraud or avoidance” online service.

To check whether another business is registered with HMRC, search the Supervised Business Register on GOV.UK. It lists only businesses HMRC supervises, and applicants appear only once registered.

How AML Buddy fits in

HMRC supervision covers your whole firm; the day-to-day work an inspector samples is your customer due diligence. AML Buddy handles the client checks: your client verifies through one secure link, and you get ID document and selfie checks, an address match, sanctions and PEP screening, adverse media and a timestamped PDF report for the file. HMRC does not approve or endorse any AML software, and your firm stays responsible for its own decisions.

AML Buddy costs £5.40 a check inc. VAT (£4.50 + VAT), with 5 free checks on sign-up and no subscription. See how it works for estate agents, letting agents and accountants.

This guide is general information, not legal advice. Check the latest HMRC guidance for your circumstances.