ECSH43531 - Accountancy service providers
Source: gov.uk (2025-02-08)


Although they carry on relevant business and are required to follow anti-money laundering policies and procedures, accountancy service providers (ASPs) which fall into the categories below are not required to register with HMRC:
- ASPs where all their customers are ASPs that are supervised by HMRC, the Financial Conduct Authority or by a professional body listed in Schedule 1 of MLR 2017 (https://www.legislation.gov.uk/uksi/2017/692/schedule/1), providing all of the following conditions are met;
- They do not deal directly with the customer of the supervised firm(s);
- They are included within the scope of the AML policies, controls and procedures of the supervised firm(s), including suspicious activity reporting and training programmes; and
- Both businesses provide evidence in the form of a written contract to confirm that the arrangement covers compliance with all the AML requirements in respect of the entire customer relationship.
- Virtual assistants who provide a small amount of accountancy services as a virtual assistant, may not need to register.
Businesses acting as ASPs will not need to register if all the following applies:
- Virtual assistant is the main business activity the annual business turnover is less than £30,000.
- No more than 5% of the total business turnover applies to accountancy service activities.
- The accountancy services the business provides, support the main business.
- There is no other business activity undertaken that needs to register under MLR 2017
- All work is reviewed by an accountant or bookkeeper who is registered for money laundering supervision.
Difference between tax advice and tax information

Tax information

When a person gives information about tax to a client, and it is the same for everyone (so their particular situation is not looked at), this is tax information. For example: giving customers, or providing links to, basic tax information that would be the same for everyone (such as the basic rate of Income Tax).

Tax advice

When a person gives tax advice however, they will have studied a client's particular circumstances, and assessed and recommended a particular course of action, or a product that is suitable for them. This applies even when the relationship with a client is for a short time only.

This means that a number of businesses that do not formally call themselves accountants will fall within the scope of the regulations. For example:
- A business supplying bookkeeping services.
- A payroll agent calculating tax liability, earnings or payments made to a business’s employees.
- A stock auditor calculating expected sales from stock records and comparing them with the takings.
- A business which helps facilitate the tax refunds of other people.
Accountancy service providers not required to register

There are a small number of ASPs who are not required to register for anti-money laundering supervision as they fall out of scope of MLR 2017, the information below sets out some of the more common scenarios.

On a non-commercial basis

Businesses who are offering accountancy services on a non-commercial basis are not carrying out accountancy services ‘by way of business (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh42525),’ and are therefore not required to register.

Accountancy services within a group

Businesses are not acting as an ASP in the circumstances below:
- For another member or part of that group.
- To a related party.
Community accountants

Community accountants can provide a variety of accountancy services to both individuals and businesses, the main question is whether they are provided by way of business. Some charge a small fee for their services, and some make no charge at all.

You will need to look at the circumstances of each case in order to make a decision, taking into account the purpose of the regulations in relation to the prevention of money laundering, and not in relation to any liability to tax.

Charging a small fee (a "nominal fee") does not necessarily mean that services are provided ‘by way of business (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh42575).’

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Where community accountancy services are provided by bodies which are registered charities, at no charge, they are currently outside the scope of MLR 2017.

Where community accountancy services are provided by bodies which are registered charities, for a small charge, but any profits could not be distributed and / or they are subsidised by grants from Local Authorities or other Government bodies, they are also outside the scope of the MLR 2017.

Insolvency practitioners

Insolvency practitioners are not required to register with HMRC for the purposes of the money laundering regulations (as they will be supervised by the Insolvency Service).

Payroll Services Provider to a third party

Payroll services provider to a third party are not ASPs for the purposes of the money laundering regulations if they only do any of the following:
- Provide software or hardware service support for payroll data processing, as long as they do not analyse or prepare any financial information.
- Pay invoiced service fees to self-employed people, umbrella companies, partnerships or other corporate service providers.
- Operate as a body such as an umbrella company or a managed service company and carry out payroll functions for employees who are working on assignments for an end-user client.
- Provide recruitment or human resources management services and carry out payroll functions as a small part of the main business activity (for example, an employment business that supplies or manages temporary or contract workers).
Customs practitioners

Customs practitioners, freight forwarders or similar, are not covered by the money laundering regulations and so are not required to register if they only provide the following services:
- Helping clients with classifying or valuing exports and imports for customs purposes.
- Helping clients to comply with customs and other procedures, for example, using simplified declaration procedures or facilities such as warehousing.
- Helping clients with import or export licensing and submitting import and export declarations on their behalf.
- Paying duties, taxes and levies on behalf of importers.
Virtual assistants

Virtual assistants who only provide a small amount of accountancy services do not need to register if all the following applies:
- Virtual assistant is the main business activity.
- The annual business turnover is less than £30,000.
- No more than 5% of the total business turnover applies to accountancy service activities.
- The accountancy services provided support the main business.
- There is no other business activity the business needs to register for under money laundering regulations.
- All accountancy service work is reviewed by an accountant or bookkeeper who is registered for money laundering supervision.
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

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