Registering with HMRC for money laundering supervision
Who has to register, why professional-body membership decides it, what the application involves, what it costs, how long it takes, and why applying late is worse than it looks.
By Mehmood Rajoka · Last updated 2026-08-12
TL;DR: Quick Summary
- •An accountancy service provider must register with HMRC for anti-money-laundering supervision unless it is already supervised by a professional body such as ICAEW, ACCA, CIMA, CIPFA or AAT.
- •You cannot choose HMRC over your professional body. Membership of a supervising body determines who supervises you.
- •New applications can take up to 45 days, and longer if HMRC needs to come back to you, so registration is not something to start in the week you plan to trade.
- •Registration is per premises, and everyone who is a beneficial owner, officer or manager goes through an approval check.
- •Supervision is annual. Missing the renewal can mean cancellation, and trading while unsupervised is an offence rather than an administrative slip.
Answer-first summary
Do I need to register with HMRC for money laundering supervision?
If you provide accountancy, bookkeeping, tax, payroll or audit services by way of business, or act as a trust or company service provider, and you are not already supervised by a professional body, you must register with HMRC. If a body named in MLR 2017 such as ICAEW, ACCA, CIMA, CIPFA, AAT or the SRA supervises your firm, that body is your AML supervisor and you do not register with HMRC as well. Supervision follows membership; it is not a choice between the two.
- HMRC supervises those without a professional-body supervisor
- Membership decides it, not preference
- Applies from when you carry on the business
- Trading unsupervised is a criminal offence
Who has to register
The third card below is where most of the confusion sits:
Accountancy service providers
Anyone providing accountancy, bookkeeping, audit, tax advice, or payroll services by way of business, where they are not already supervised by a professional body. A sole practitioner is in scope on exactly the same terms as a large practice.
Trust or company service providers
Firms forming companies, acting as or arranging directors or secretaries, providing registered offices, or acting as or arranging trustees. Company formation work is squarely in scope, which catches practices that do it as a sideline.
Not you, if a professional body supervises you
If you are supervised by ICAEW, ACCA, CIMA, CIPFA, AAT, the SRA or another named body, that body is your AML supervisor and you do not register with HMRC as well. This is the single most common point of confusion.
Before you start trading
The obligation attaches to carrying on the business, not to reaching a turnover threshold. Because approval can take 45 days or more, an application submitted after work has started is already late.
How the application works
Four stages, and the first one saves the most money:
1. Confirm who supervises you
Check your professional body membership first. If a body listed in MLR 2017 supervises you, registration with HMRC is not required and applying anyway wastes the application fee.
2. Prepare before applying
You will need details of every premises, and of every beneficial owner, officer and manager for the approval check. Having a firm-wide risk assessment and written policies already in place is expected, because supervision begins at registration rather than at the first inspection.
3. Apply and pay
The application is made through HMRC's online service and the fees are paid at the same time. Allow up to 45 days, and longer if HMRC comes back with questions.
4. Renew annually
HMRC emails towards the end of the registration year. Late payment can lead to cancellation, and the consequence of trading unsupervised is materially worse than the consequence of paying late.
What it costs
Registration is charged in several parts rather than as one fee:
- A one-off application fee, payable when you apply and not refunded if the application is refused.
- A premises fee for each address included in the application, charged again at each annual renewal.
- An approval-check fee for every beneficial owner, officer, and manager tested as part of the application.
- Annual renewal covering each premises on the registration, due at the end of each registration year.
- HMRC publishes the current figures, and they are reviewed periodically. Confirm the amounts on GOV.UK before budgeting rather than relying on a figure quoted anywhere else, including here.
Registration establishes who supervises you. It does not discharge any obligation. A newly registered firm is expected to already hold a firm-wide risk assessment, written policies, and a record-keeping process, because supervision starts at registration rather than at the first inspection.
FAQ
Answer-first summary
Do I need to register with HMRC for money laundering supervision?
If you provide accountancy, bookkeeping, tax, payroll or audit services by way of business, or act as a trust or company service provider, and you are not already supervised by a professional body, then yes. If you are supervised by ICAEW, ACCA, CIMA, CIPFA, AAT, the SRA or another body named in MLR 2017, that body is your supervisor and you do not register with HMRC as well.
Answer-first summary
How do I register with HMRC for money laundering supervision?
Apply through HMRC's online money laundering supervision service and pay the fees during the application. You will need details of each premises and of every beneficial owner, officer and manager, because each of those people goes through an approval check. New applications can take up to 45 days, and longer if HMRC needs further information.
Answer-first summary
How much does anti-money-laundering registration cost?
There is a one-off application fee, a fee for each premises included, and an approval-check fee for each beneficial owner, officer or manager tested. Registration then renews annually with a premises fee for each address. HMRC publishes the current figures on GOV.UK and reviews them periodically, so confirm the amounts there before budgeting.
Answer-first summary
How long does HMRC AML registration take?
Up to 45 days for a new application, and longer where HMRC needs to contact you for more information. Because the duty attaches to carrying on the business rather than to a turnover threshold, an application started after trading has begun is already late, so it is worth applying well ahead of taking on the first client.
Answer-first summary
Can I choose to be supervised by HMRC instead of my professional body?
No. Supervision follows membership. If a professional body listed in MLR 2017 supervises your firm, it is your AML supervisor. HMRC supervises the sectors that do not have a professional-body supervisor, which is why it is sometimes described as the default supervisor rather than an alternative one.
Answer-first summary
What happens if I do not register?
Carrying on a business in scope of MLR 2017 without being supervised is a criminal offence, not an administrative oversight. HMRC can impose penalties, publish details of the business, and in serious cases pursue prosecution. Registration being pending is not the same as being registered.
Answer-first summary
What is the fit and proper or approval check?
HMRC tests each beneficial owner, officer and manager before approving a registration, checking for relevant criminal convictions and other factors bearing on suitability. For trust or company service providers and certain other sectors this is a formal fit and proper test. A fee is charged per person tested, and the check is part of why applications take time.
Answer-first summary
Do I still need my own AML policies if HMRC supervises me?
Yes. Registration establishes who supervises you; it does not discharge any obligation. You still need a firm-wide risk assessment under Regulation 18, written policies and controls under Regulation 19, a nominated officer where required under Regulation 21, customer due diligence under Regulation 28, training, and record keeping under Regulation 40. Supervision means those will be inspected.
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Related guides
Firm-wide AML risk assessment
Regulation 18: the document supervision expects you to already hold.
Money Laundering Regulations 2017
The framework registration places you under.
HMRC AML inspection
What happens after registration, and what inspectors ask to see.
AML policy template
The written policy Regulation 19 requires.
What is an MLRO
The nominated officer role and when it is required.
AML checks explained
What supervision will hold you to on every client file.