The Treasury has made the Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026 under section 249 of the Finance Act 2026. The instrument, signed on 13 July 2026 by Deirdre Costigan and Taiwo Owatemi as Lords Commissioners of His Majesty's Treasury, sets the commencement timetable for the HMRC registration regime for tax advisers. According to the text published on legislation.gov.uk, the policy now moves from framework legislation into an operational timetable. The main start date is 18 August 2026, but the Regulations provide later commencement dates for defined groups of advisers and a deemed-registration rule for some firms already using HMRC's agent infrastructure.
One part starts earlier than the main registration timetable. The Regulations appoint 14 July 2026 as the date on which Chapter 1 of Part 7 of the Finance Act 2026 comes into force, so far as it is not already in force, for the limited purpose of making regulations under section 247 of that Act. That point is technical but important. Section 247 gives the Treasury power to amend Schedule 20, which deals with exceptions to the registration regime, so the exception-making power is available from 14 July 2026 even though the wider operative duties do not apply to every adviser on that date.
For the substantive regime, the default position is the first tranche. The Regulations state that Chapter 1 of Part 7 comes into force for all remaining purposes on 18 August 2026 for any tax adviser who is not placed in a later tranche. That makes 18 August 2026 the effective commencement date for most firms. The drafting is structured so that later dates are exceptions rather than the norm, which means advisers need a clear basis in the Regulations before assuming they have additional time.
The second tranche begins on 18 November 2026. Under the Regulations, this applies where a tax adviser did not have an Agent Services Account immediately before 18 August 2026 but did have a specified tax account, defined in the instrument as a Self-Assessment Account or Corporation Tax Account, and does not fall into the third or fourth tranche. The practical effect is to distinguish between advisers already using HMRC's Agent Services Account model and those still operating through older online service accounts. For firms in that position, the relevant compliance test is not simply whether they filed online, but which HMRC communications authorisation they held immediately before 18 August 2026.
The third tranche starts on 18 February 2027 and is narrower. According to the Regulations, it applies where an adviser did not have an Agent Services Account immediately before 18 August 2026 and, during the period from 18 August 2026 to 17 February 2027, their only tax adviser activities are payroll services. The instrument defines payroll services as the delivery of information, or the making of payments, to HMRC in accordance with PAYE regulations. That gives a specific deferral to payroll-only providers, but the condition is strict: if the adviser carries on wider in-scope tax adviser work during the relevant period, the later date may no longer apply.
The fourth tranche comes into force on 1 April 2027. The Regulations place an adviser in that tranche if, immediately before 18 August 2026, they did not have an Agent Services Account and, during the period from 18 August 2026 to 31 March 2027, their business consists to a substantial extent of carrying on one or more regulated activities, or their clients are to a substantial extent group undertakings and one or more group undertakings in the corporate group carries on regulated activities to a substantial extent. The drafting imports the meaning of regulated activities from the Financial Services and Markets Act 2000 and the meaning of group undertaking from the Companies Act 2006. In policy terms, that gives additional lead-in time to some financial services businesses and group structures where tax adviser activity sits alongside regulated operations.
The transitional provision is likely to be the most significant operational measure for firms already inside HMRC's current agent framework. Where an adviser held an Agent Services Account immediately before 18 August 2026, the Regulations treat Chapter 1 of Part 7 as if the adviser had made an application under section 225, had that application approved under section 230, and had been notified that registration took effect from 18 August 2026. For existing Agent Services Account holders, that removes the need for a fresh application at commencement and provides continuity from 18 August 2026. The Explanatory Note also states that the Tax Information and Impact Note published on 26 November 2025 alongside Budget 2025 remains an accurate summary of the impacts. The immediate task for firms is to evidence their account status immediately before 18 August 2026, document the services they provide during the relevant statutory windows, and test carefully whether any later tranche applies under the wording of the Regulations.