Autumn Budget 2025: No regulation of the tax profession

Susan Cattell highlights an Autumn Budget announcement on tax regulation.

In 2024 HMRC issued a consultation which set out the case for improving the tax advice market and outlined three potential regulatory models. This was the latest in a series of consultations since 2020 on improving standards in the tax advice market.   

We have consistently called for the introduction of a requirement for all tax advisers to belong to a professional body, as the best option for raising standards across the market. Along with the other professional bodies which belong to the Professional Conduct in Relation to Tax (PCRT) group we supported this option in the 2024 consultation. 

Autumn Budget 2025 announcement – regulation won’t proceed 

It’s disappointing that in spite of majority support for this option in responses to the 2024 consultation, the current government has decided not to proceed. There will be no regulation of the tax advice market in this parliament.  

However, the government will include legislation in the Finance Bill 2025-26 giving HMRC enhanced powers to target advisers who deliberately facilitate non-compliance. From 18 May 2026, all tax advisers who interact with HMRC on behalf of clients must also register with HMRC. We’ve been involved in discussions with HMRC about the details of these measures, which have raised some concerns. 

Our position 

Our members providing tax advice must meet knowledge, skills, and experience requirements for initial admission to membership, ongoing licensing and conduct requirements, and must maintain professional indemnity insurance and their professional knowledge (through CPD). By contrast, unregulated tax agents are free to provide services to clients without any protections in place in relation to competence or conduct. While there are many agents in the unregulated population who do good work for their clients, we believe that bad practices are more likely to arise among unregulated tax agents than those who are members of a professional body. With the public not well-informed about the differences between regulated and unregulated advisers, we continue to believe that there’s a clear public interest rationale to support a regulatory framework. 

Professional Conduct in Relation to Taxation (PCRT) is a key component of professional standards for tax advisers belonging to ICAS and the other six professional bodies that adopt and maintain it. It applies to all tax work and includes specific standards on tax planning. The latest version of PCRT was published on 1 October and will take effect from 1 January 2026. PCRT is also adopted by two other professional bodies (and recognised by the Solicitors Regulation Authority), as well as being endorsed by HMRC (it forms the basis for HMRC’s own standard for agents). 

Future engagement 

We look forward to continued engagement with HMRC on how progress can be made in improving standards across the tax advice market and tackling the minority of incompetent, unscrupulous and unprofessional tax advisers, in the absence of a regulatory framework. It’s very important that any further piecemeal measures introduced to address problems caused by the minority of poor advisers, don’t have unintended adverse consequences (including imposing additional burdens) for the majority of tax advisers who are competent and adhere to high professional standards, particularly PCRT. 

Let us know what you think 

We respond to tax consultations and calls for evidence and attend meetings with HMRC at which service levels, delays and other issues you raise with us are discussed. We welcome input from members to inform our work; email us to share your insights and feedback. 

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