Foundations
Part of Accounting services foundations for the 2027 MTD shift
Accounting services market entry checklist for UK practices
This accounting services market entry checklist for UK practices covers scope, supervision, HMRC agent registration, client terms, systems and controls.
Complete this accounting services market entry checklist before taking on client money or records. The exact requirements depend on the legal entity, services, professional memberships and customers. Obtain specialist advice where the position is uncertain.
What to take away
- Determine your anti-money-laundering supervisorHMRC or a professional body such as ICAEW, ACCA, AAT, CIOT, ICAS or IPA — and complete registration under the Money Laundering Regulations 2017 before you trade or take client money.
- Define each service, customer type and complexity limit, and list work you will not accept.
- Verify identity, authority and record quality before promising a fixed timetable or fee.
- Prove the model with a small eligible customer group and stop intake when safe capacity is reached.
- Approve market entry only when every mandatory item has evidence and a named owner.
Define the offer
- Name each service and the customer outcome it supports.
- Separate bookkeeping, accounts preparation, payroll, tax compliance, tax advice, company secretarial work and management reporting.
- Exclude statutory audit unless the practice holds audit registration with a recognised supervisory body and meets the independence framework.
- Specify customer types, legal forms, industries, territories and complexity limits.
- List work the practice will not accept and the escalation path for unfamiliar matters.
- Map each task to an accountable person and competent reviewer.
Establish the business and authority
- Choose the legal structuresole trader, partnership or limited company registered at Companies House — and complete the relevant registrations.
- Check whether each title, designation and professional-body claim may be used.
- Assess professional indemnity and other insurance needs against actual services and any minimum cover the relevant professional body requires.
- Create conflict, independence, complaints and continuity processes.
- Record who may bind the firm, sign work, submit information and operate client accounts.
Meet supervision and agent requirements
- Determine whether the work falls within the accountancy-service-provider definition in the Money Laundering Regulations 2017.
- Identify the correct anti-money-laundering supervisor before trading: HMRC supervises accountancy service providers that are not supervised by a prescribed professional body, while ICAEW, ACCA, AAT, CIOT, ICAS or IPA supervise their own members. OPBAS oversees those professional body supervisors.
- Register with HMRC for money laundering supervision, or complete the equivalent professional body registration, before you trade; HMRC publishes a register of the businesses it supervises.
- Appoint a money laundering reporting officer and report suspicious activity to the National Crime Agency under the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
- Design customer due diligence, risk assessment, monitoring, reporting, training and record controls, and keep customer due diligence and transaction records for five years after the business relationship ends.
- Register as an HMRC agent through the agent registration service and the Agent Services Account, and file form 64-8 or the equivalent authorisation for each client.
- Obtain the required agent accounts, service enrolments and client authorisations.
HMRC explains money-laundering supervision for accountancy service providers, including virtual and automated services, and publishes a register of the businesses it supervises. Its tax-agent registration guide covers a separate process. Do not confuse either with ordinary business tax registration.
Supervision and agent registration
- Check accountancy-service-provider definition
- Identify anti-money-laundering supervisor
- Register or document supervised exemption
- Design due diligence and record controls
- Assess tax-adviser registration for HMRC work
- Obtain agent accounts and client authorisations
Control client acceptance
- Verify identity, ownership and authority using approved evidence.
- Understand the requested purpose, prior adviser and reason for change.
- Inspect record quality before promising a fixed timetable or fee.
- Check conflicts, sanctions and risk factors under the applicable procedure.
- Confirm competence, capacity and deadlines before acceptance.
- Send an engagement letter defining scope, responsibilities, assumptions, fees and termination.
- Complete a professional handover where required and authorised.
Protect information and systems
- Map personal and confidential data, purpose, access, retention and transfers under UK GDPR, and register with the Information Commissioner's Office where the practice acts as a data controller.
- Use individual accounts, strong authentication and role-based permissions.
- Prohibit clients from sharing their HMRC sign-in details.
- Review bookkeeping, tax, payroll, document and communication suppliers.
- Test backups, restore, incident response and alternative deadline routes.
- Keep source evidence, review notes, submissions and acknowledgements together.
The HMRC standard for agents expects agents to protect information, maintain competence and take reasonable steps over third-party input. Translate those expectations into observable controls.
Prove the model before scaling
- Cost review, correction, supervision and non-routine communication.
- Define volume bands and the process for scope changes.
- Pilot with a small, clearly eligible customer group.
- Measure errors, missing records, write-offs, client effort and deadline margin.
- Review complaints, incidents and near misses.
- Stop intake when safe delivery capacity is reached.
Approve market entry only when every mandatory item has evidence and an owner. A polished website cannot compensate for absent supervision, vague engagements or a team that lacks time to check its work.
Schedule a post-launch review after the first complete reporting cycle. Sample accepted and rejected files, reconcile promised scope with recorded work and ask clients where responsibilities were unclear. Correct templates, training and prices together. If the control depends on one person's memory, write and test a repeatable procedure before adding more clients.
Before you act
- Name each service and its customer outcome.
- Identify the correct anti-money-laundering supervisor and register under the Money Laundering Regulations 2017 before trading.
- Register as an HMRC agent and put client authorisations in place.
- Send an engagement letter defining scope, fees and termination.
- Map personal and confidential data under UK GDPR and register with the ICO.
- Pilot with a small, clearly eligible customer group.
- Schedule a post-launch review after the first reporting cycle.
Common questions
When should I register with an anti-money-laundering supervisor?
Identify the correct supervisor before trading: HMRC supervises accountancy service providers that are not supervised by a prescribed professional body, while ICAEW, ACCA, AAT, CIOT, ICAS and IPA supervise their own members under the Money Laundering Regulations 2017. Complete registration, or document the exact supervised exemption. Then appoint a money laundering reporting officer, design customer due diligence, risk assessment, monitoring, reporting, training and record controls, keep records for five years, and report suspicious activity to the National Crime Agency under the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
What must I check before accepting a new client?
Verify identity, ownership and authority using approved evidence. Understand the requested purpose, prior adviser and reason for change. Inspect record quality before promising a fixed timetable or fee, and check conflicts, sanctions and risk factors. Confirm competence, capacity and deadlines, then send an engagement letter defining scope, responsibilities, assumptions, fees and termination.
How do I know the practice is ready to scale?
Cost review, correction, supervision and non-routine communication. Define volume bands and the process for scope changes, then pilot with a small eligible group. Measure errors, missing records, write-offs, client effort and deadline margin. Review complaints and incidents, and stop intake when safe delivery capacity is reached.
