Enrolment - not too scary? | AccountingWEB

Enrolment - not too scary?

I've posted a detailed analysis of the enrolment procedure that HMRC envisage on the main site, to get as wide an audience as possible, but if you want to debate some of the pro's and cons in a bit more detail, I though I would start a thread here on the topic too. My reading of the enrolment proposal is this :

  • I had originally thought that HMRC only wanted us to enrol for self serve so if we didn't want to self serve we didn't need to enrol
  • the meeting last week clarified this for me, and I realised that HMRC's proposal - but subject to the outcome of the consultation is - is that ALL paid professional agents will need to enrol so that HMRC has a clean list of agents to work from. They don't presently have such a list. This seems eminently reasonable to me - they just want to know who they are dealing with.
  • voluntary organisations and thier volunteers (like TOP volunteers) will be on a separate list
  • HMRC are absolutely aware of the issue of restraint of trade (as expressed most eloquently by C_D) and intend that if this is brought in ALL paid agents will be invited to enrol.
  • That's all there is to it folks.

This is not about regulation. It's about a list of people they trust, because they know who they are and where they are.

Over to you...




accountright | | Permalink

and will there be a cost associated with this?  That is my main concern as I already pay my own professional body to make sure I am "clean" and I have to jump through hoops every now an again to keep my practicing certificate.


RebeccaBenneyworth's picture

no charge

RebeccaBenneyworth | | Permalink


Old Greying Accountant's picture

Does nobody else feel as I ...

Old Greying Acc... | | Permalink

... that it is a farcical situation that HMRC does not have a list of agents and needs us to enroll, or rather, it is easier and cheaper for them make us enroll rather than process the data they already hold.

What is criminal is that they had a network of local offices with detailed knowledge of all agents which they threw away, and now want us to pick up the pieces for them, which we will, because our livlihoods depend on it, and the easier and more efficent correspondence with HMRC is, the better chance our practices have - we do not have the luxury of an indexed linked final salary pension, generous leave entitlement etc etc so the more profitable we are the more chance we have of at least having a modest pension when we retire (if we live that long and don't all have strokes caused by the stress of dealing with HMRC!).

ShirleyM's picture

Agent codes

ShirleyM | | Permalink

As HMRC issue agent codes don't they have this information already?

Are they looking to identify the accountants that do not register as agents?

daveforbes's picture

Professional help

daveforbes | | Permalink

One of the questions the HMRC want to know the answer to is which ( or even the how many ) returns are completed by professional accountants as oppose to DIY or "unrepresented taxpayers".

Unfortunately there are tens of thousands of "agents" that complete less than 5 returns. They may be registered as agents, but many are just individuals doing elderly relatives returns for them.

Equally odd are the significant % of £billion+ companies that fall into the "DIY" category.

They may have data, but it needs a lot of cleansing to become useful.


chicken farmer | | Permalink

Lets be clear about ‘enrolment’. You say “that ALL paid professional agents will need to enroll” and later “ALL paid agents will be invited to enroll”. An ‘invitation’ implies that enrolment is voluntary. The condoc says “HMRC considers that enrolment should apply to all paid agents”, in other words it will be compulsory (and no doubt there will be penalties imposed on those who fail to enroll).

This may not be called regulation but as the saying goes, if it walks like a duck and looks like a duck ......

So whats the problem?

pauljohnston | | Permalink

If all paid agents are already known by HMRC this is not a problem.  For those paid but not known to HMRC it may be a problem.  It is this second group that are effectively under the radar that HMRC will now be aware of.


Marion Hayes's picture

Classes of agent

Marion Hayes | | Permalink

As I read the document originally there will be three types of agent HMRC will engage with.

Paid agents who register as such who will be given greater rights and facilities, even if they choose not to use them. 

Volunteers who will be on a separate list

and everyone else

I did not see any indication that those in the third category would be any less able than today to act for clients, just that they would not get agent extras - so I cannot see how there would be penalties for not enrolling. Other than it will remain potentially slower to act for your clients.

I am concerned with practicalities. At the moment I have Agent references online for SA, CT, VAT FILING, PAYE & CIS.  I operate 3 payrolls, one on a voluntary basis. I complete and file a couple of very simple VAT returns but do not act for anyone on VAT  as I haven't the knowledge, I carry out corporation tax computations and file the CT returns but don't do the accounts as I am not an accountant. I volunteer for TOPs and CAB. I help on a paid basis accountants who do not have their own tax staff, or tax confidence, or just do not have the right tax software. I have personal tax clients, business tax clients, friends/family (who are not always charged), as well as some people I help who cannot afford to seek the real help they need. I offer consultancy services to clients where I am never involved with HMRC anyway. My practice is very small.

How will I be classified? 


-- Marion


chicken farmer | | Permalink

Forget self serve, the underlying reason for enrolment is so that the Revenue can monitor the activities of tax agents. They will create an ‘agent view’ and use that data to “identify agents with high standards in their field, agents who need help to improve their standard of work and the very few agents who act dishonestly”.

It would be rather self-defeating therefore to allow enrolment to be voluntary – the crooks would simply slip under the radar. So to ensure that the Revenue are aware of all agents, enrolment must be mandatory and there must be penalties for failure to enrol.

RebeccaBenneyworth's picture

A few answers

RebeccaBenneyworth | | Permalink

The concept of an old list might be a bit imaginary. There might have been a little black book with the DI, or it might be a legend. However, we need a clean, complete list of professional agents who can be verified - i.e. we know thay are who they say they are, and we know where to find them. (They're not some figment of a fraudster's imagination). So the list created will be secure and clean. I can't myself see a pronblem with a clean list of agents.

Those who volunteer for TOP, TaxAid, etc will be covered by separate arrangements which will apply to the number of not for profit organisations which operate in this area. I'm a TOP volunteer, and this part is quite separate from my paid agent work, and I use my TOP arrangements if I need to contact HMRC. I do keep these separate.

As to a list of agent codes - this doesn't really work, as it is not one merged list, and there are all sorts of other "people" on it - like my tax software company which sometimes submits custokmer returns for them when they have had big problems. We(software company) wouldn't be on the agent list.

No there would not be any penalties if you are not enrolled, but as the new list is of all paid agents, you would not have access to the agent system - and I guess that may mean losing some of what you have now. Friends and family will come under a different relationship which has not been addressed in this document as it is not the subject under debate.

For Marion. If you have paying clients, then you will be able to enrol as a professional agent. If you do a few free returns for people that isn't going to change the fact that you are a paid professional agent and will register as such.

And for chicken farmer. It's a list. HMRC do not want to regulate agents. "HMRC believes that structured self governance of the tax agent market is the correct model for a future relationship". To quote the quote from Dave Hartnett "HMRC has neither the resources nor the competence to do so". I'm not sure how many other ways to put it. This consultation IS NOT about regulation of the tax profession. The professional bodies have been satisfied as to that otherwise they would be shouting from the rooftops to their members that this needs to be resisted at all costs. (I guess you agree? That at least some (if not all) of the bodies might feel a bit threatened by HMRC trying to cut them out? I can tell you that with my ICAEW hat on I would be screaming blue murder if I thought my body, and my fellow members were being sidelined by this). OK maybe you don't believe HMRC, but the leaders of our profession have all accepted this message. There are some very smart people representing the professional bodies on this .... they can't possibly ALL be wrong. Unless you know better?

I agree with OGA

david wilks | | Permalink

HMRC do have details of all agents who are registered for online services, registered under the Money Laundering regulations and for their own personal and/or corporation tax. Why on earth do they need another list? Surely they should just spend a little time collating these lists. Then, if new names start popping up they can require them to be enrolled.


RebeccaBenneyworth's picture


RebeccaBenneyworth | | Permalink

in the consultation document is the penalty for failure to enrol set out? I have clearly missed this.

The agent view is a separate part of the consultation, which I shall be writing about in 10 days or so when we have dealt with this area. I know they will start the agent view with a list of agents, that much seems obvious. But there is no point getting into agent view here. We may say we don't like the agent view bit, that we don't agree with it. But that does not alter the fact that they need a secure list of agents.

Marion, I hope my answer above is clear.

Following Australia...

dpeart195 | | Permalink

Enrolment for paid agents should not come as a great surprise to us.   When self-assessment was introduced I was Tax Manager at a London firm, and I was lucky enough to have a Tax Senior on secondment from Australia.   He laconically observed that what was happening here was following the Australian model, and had already been introduced 'back home'.  

You can look at the details of the Tax Agent Services Act 2009 at www.tpb.gov.au.   The information sheets give a template that might be the kind of thing that HMRC are suggesting, and we can form our own opinions using this as a background.

My own observations are:

1.   This initiative must be properly introduced following an Act of Parliament after proper discussion and consultation with all parties.

2.   Formal registration should give some recognition to the Agent - perhaps an enrolment number

3.   The Agent Register should be available for public inspection

4.   Agents should be able to update their information online rather than be required to validate their information annually

5.   There should be no cost to the Agent.

Reading the information sheet in more detail will reveal more ideas - but it might be useful to draw on the Australian experience rather than re-invent the wheel.   After all, we have already done this in the past.

Another quick thought:   how will HMRC issue invitations to enrol if they do not already hold a list of Agents?






Old Greying Accountant's picture

As in all govenment initiatives ...

Old Greying Acc... | | Permalink

... there are gaping holes.

The ones who need to be monitored will do as many have said, do and get paid for the work but file under the tax payers individual identity not as an agent. If they are disreputable, they will not care about self serve of increased access to resources.

And David, as an agent I have an access code to allow my system to file online returns. As a "lay" person when it comes to IT, I don't see it can be that hard to work out how many returns are submitted by which agent. Why not just make it mandatory for self serve agents to file online. As to needing lots of data clensing, they should have taken more care and not dropped it in a dirty puddle. The sheer ineptitude of those in charge of HMRC is becoming more apparent by the day. I refer to the last 10-20 years, and hopefully the current incumbents are getting to grips with the issues, but I am beyond angry that HMRC was allowed to get in to the shambles it is in the first place, and no one seems to have been brought to account for it. It has patently failed to grasp even the most basic business strategies and done no forward planning of any consequence.

I also find some of the enrolment criteria sinister, such as ensuring the agents own tax returns and liability are dealt with on time - how does that affect your ability to be an agent? The other information they have already.

Do you think I  would have many clients if I had to keep saying, I know I already have this data on you, but can you let me have it again please, and again, and again ...

As an aside, apart form the trust issue, which in terms of HMRC as a body, I still have none, a large part of their problems, which is not in their control, is resentment of tax payers in paying taxes when the government a) talk a good talk but show no signs of curbing their excesses and b) squander billions on causes that few tax payers support whilst ignoring those they do.

voluntary enrolment?

chicken farmer | | Permalink

Do you not accept that the Revenue want enrolment to be mandatory?

If so can you think of any other piece of mandatory tax legislation which does not have a penalty regime attached?

Old Greying Accountant's picture


Old Greying Acc... | | Permalink

Rock and a hard place!

Which to be, the boy who cried wolf, or the one who said "the Emperors got no clothes on"?


Chris Wise | | Permalink

I can see how existing agents might be asked to enrol, but what of the many people who set up micro businesses as a sideline, or even full practices in the future? Where will their invitations be issued from?

I'm not even convinced it will cut down on the fraud, Fraudsters will just enrol, make a batch of bogus claims and then disappear. Or worse piggyback on a bona fide agent's access, as we see from time to time now.

RebeccaBenneyworth's picture

"Spend a little time"

RebeccaBenneyworth | | Permalink

We are moving to a new secure environment. The lists have loads of people on them who will not be able to get into the new secure environment because they aren't real. Some of them are "tax return repayment factories" not based in the UK. Some of them are people who registered as an agent to do their dad's tax return 12 years ago and haven't doen anything since. Collating lists which are incomplete and contain a lot of duff data isn't sensible. Clean data which is secure is the way forward. And HMRC needs data items which they don't currently have - like email addresses - to increase security. We're talking here about no more security checks when we phone (or they phone) and significant benefits for our clients through reduced risk scores (see the main article). I really don't see how a one time enrolment can be suh an issue. Yes they should have it already - I agree. But they haven't.

RebeccaBenneyworth's picture

Picking up OGA's point

RebeccaBenneyworth | | Permalink

Can we have some comments on checking whether you are tax compliant on enrolment. I thought more people would comment on that one?

johnjenkins's picture


johnjenkins | | Permalink

normal circumstances I would probably agree with the worry of HMRC's actual program and no doubt WD (if he were allowed) would give no end of reasons why we should resist any attempt of control by HMRC.

However I don't think they have anywhere else to go, so where is the starting point? Get principles agreed by "bodies" and "institutions" and then hand it all over to us.

Do we not have enough confidence in our ability to get the system changed?????????

We certainly can't do it from the outside unless we take really drastic action "together", which won't happen. So once enrolled and "allowed" in we can then see what is causing the problems and suggest ways of changing their "modus operandi". This could be the only opportunity we (agents) have now of actually achieving real progress with HMRC. We should embrace it with our natural awareness.

What's the worst that can happen? We are back where we started from.


Logic and or paranoia

mpurcell | | Permalink


If there is a 'list' someone (HMRC?) has to 'keep' it.

There will, no doubt, be some criteria needed to allow/enable you to be on the list. If there is not, there is no point in having the list otherwise anyone could enrol (Mickey Mouse) and benefit from the additional functions offered to agents.

So there is the problem.

HMRC will have jurisdiction over who is on the list. How will they exercise this power? Well who knows? Personally, I am sure they will do an excellent job, be fair, reasonable, and easy to contact whenever there is any dispute or disagreement about the data or eligibility. In support of this statement I would point you to their long track record.

Oh ... and there is no intention to control or monitor  those on the list .... so why the references in the ConDoc to targeting those agents who fall outside the norm ?


Think me paranoid if you will but if I had painted a scenario to you 10 years ago of the  situation we find ourselves in today what would you have called me then?

 Perhaps I do not know better than all the great and good or there again ...

What has changed?

mpurcell | | Permalink

I hear what you say John but what has stopped us from changing things up to now?

Answer HMRC could not give a damn. If this is no longer the case well let them prove it.     First. 

No control eh? Well as you ask Rebecca what about agents having to show their own tax affairs are up to date .. sounds like control to me !

Picking up OGA's point - checking whether you are tax compliant

Scotton | | Permalink

 Completely agree that tax compliance of the agent at enrolment is an an unnecessary intrusion and of no impact as to the agent's capacity to perform. I think we should resist this element strongly - how are the other bodies responding? I can't believe that senior partners at global firms will be happy with this aspect. Or - yet again - will the the big boys have so much resource to throw at the problem it won't have an impact? My worry is that once more the whole system that HMRC designs is not user friendly to anyone other that an enterprise above a certain size.  In addition I have great reservations as to HMRC's security capacity and their capability for this new data linkage to not be part of yet another database 'loss'. The 'new start database' seems to be part and parcel of the whole chaotic software systems ??? at HMRC. No matching of online enrolment codes to agent particulars; no matching to MLR registration etc etc. Finally; we should all be aware that this is just the true indication of HMRC's intention to have a fully integrated 'global' database; and in their inimitable fashion [in fact all Gov't dep'ts are the same] want as much information as possible "just in case and so we don't need to ask you for it in future". It will also be; in the future; part of a linked access database to all other facets of Gov't. Access rights and control of same are the future problem.

Rant of the day over!!!!

Bottom line has to be a two fold approach: a) be pragmatic and lets see what, if anything, we can do to mitigate the worst probable excesses of this 'proposal' and b) use whatever networking /contacts/pressure points available to create publicity about this being the thin end of the wedge as regards the information database.

Agent's compliance

BKD | | Permalink

I have already indicated in my own response to the ConDoc that the agent's compliance status is an irrelevance to the enrolment process (it will undoubtedly be the case that there are some agents whose incompetence in dealing with their clients' affairs goes hand in hand with a lack of diligence in respect of their own affairs, but it is completely inappropriate to suggest that the two necessarily go together, and this element should be withdrawn from the proposals).

RebeccaBenneyworth's picture


RebeccaBenneyworth | | Permalink

Whether or not we have a new list of enrolled agents, HMRC now has the power to "disengage" with an agent. The power has been tested in court recently, but that power exists now, and will do under the new enrolment scheme - I don't dispute that. I would like to keep discussions about that part separate as it stands or falls alone (i.e. whether enrolment were to happen or not) and I have some strong views about what I think should or should not happen around that. I'll write it up a bit later in the consultation period and give my own views on what safegurads I think are necessary.

However, to get a clear picture of your views on registration / enrolment alone, I'm trying to keep them separate as we can do one without the other, or the latter without the first (if you get my drift). So it makes sense to me to take them separately. If you think enrolment should be dependent on adequate safeguards over "disenrolment" can we take that up at the disenrolment debate, and I'll link together in our response.

Does anyone else take the view that enrolment should be statutory? Or is it really disenrolment and the safeguards that should be statutory, in which case, again I'll pick that up for debate a bit later if you bear with me?


Scotton | | Permalink

 I've obviously been asleep as I thought the original HMRC document was publicised as being 'an option' for those wishing to to 'self serve'.  Interesting to note that there is now 'mission creep' to now expect ALL agents to enrol whether wishing to self serve or not. Thanks for highlighting this Rebecca. Did you get any feedback from HMRC at your meeting that this 'new' position was likely to be sensibly effected by responses in this 'consultation' period. Or is like most HMRC's consultations - give it some air time to allow steam to be vented and then we'll do what we had originally planned anyway? 

pawncob's picture

Time was.......

pawncob | | Permalink

This is not about regulation. It's about a list of people they trust, because they know who they are and where they are.

There was a time when I was known to the local I of T, and I did all I could to maintain my good reputation. My firm suffered very few investigations because we had a good reputation. It was all about risk management, but with a human face.

Now I am just a number (Agent No. W32446...) to them. They don't know who I am and I no longer have any contact with my local office because they've moved all my clients to the outer reaches of Edinburgh etc.

Can someone explain to me how registration will improve my relationship with HMRC?

As with MLR, it's a sledgehammer to crack a nut. That's why they're amending the MLR rules to take small businesses out of the net.

RebeccaBenneyworth's picture

Mission creep

RebeccaBenneyworth | | Permalink

I think it was probably my fault. One of the questions asks whether enrolment should happen when agents enrol for self serve, so I assumed that you only needed to enrol if you wanted to use self serve. That may well be an outcome if the responses are clear. But I did ask the question, and was told that HMRC's proposal is that all paid agents will enrol. It may be that HMRC has assumed that all paid agents will want access to self serve, but responses may indicate that some don't want self serve and don't want to enrol either. Whether they would then be able to act as agents with the current levle of functionality is not clear from the proposals, but your comments can fill that space.

I am interested in the resistance to this here, when by my guess 100% of the agents at the meeting I attended saw absolutely no issue with it at all.

johnjenkins's picture

There isn't

johnjenkins | | Permalink

an issue with enrolment, just the strings that are likely to be attached to it.

As we weren't at the meeting we can't get an idea of how this was presented. If the presentaion was such that you give your deatails in exactly the same way as for the "gateway" then there isn't an issue.

Is there a prototype copy of the enrolment form for perusal?????

Marion Hayes's picture

Responses - thanks for comments

Marion Hayes | | Permalink

What a time to pick to go to the dentist!!

It makes perfect sense to start a new list as the number of duplications - ELS to FBI alone created hundreds- and as in my case many references to one practice would be a nightmare database to cleanse.

Thanks for the explanations Rebecca - my concern  about being mixed is addressed, but one I didn't mention  relates back to a paragraph I just can't seem to see at the moment - perhaps it was in commentary rather than the Condoc - which related to size being an enrolment factor. If I exclude all my voluntary and friends etc there are not a lot of 64-8 (for want of a better description) left.

New businesses already have to register with HMRC for UTR's etc - I assume that the online registration system for online services will be the tool to confirm all the data details are correctly encaptured.

They have published a datset to enrol - if you cannot supply the mandatory information you will be excluded anyway. These are matters of fact so there will be no subjectivity. I have no problem supplying a UTR - but definitely do not accept that personal performance after registering should affect enrolment - cobblers and shoes come to mind!! I also feel that bank account and professional body should be excluded from the dataset, with  MLR, Data Protection and PII information required.

Rebecca - I don't think enrolment should be statutory but safeguards and disengagement definitely should

Whilst I hesitate to throw fuel on the flames I also feel that membership of a professional body is an irritant to any identification of the kind of agent a practice is. HMRC need to take on board that any one firm could have a constantly varying mix of QBE and Qualified. They would better be able to judge the expected impacts if they judged the firm on overall numbers of employees.  Perhaps Rebecca you could post this thought on the relevant thread for me





Mission creep et seq.

Scotton | | Permalink

One of my real reservations about the whole scenario is my lack of trust in HMRC's capacity to secure the data - either internally by 'loss' - or externally by 'hack'. At the present the firewalls - accident of history/incompetence - of separate data in separate databases at least gives me a modicum of comfort as to the consequence of data loss. I have no such comfort level if HMRC have one large multi-faceted database.

To return an earlier point: I have no desire and can see no need for my access privileges to be interrelated with my clients tax affairs. This is like saying that a barrister who solely defends in criminal cases should have their access rights to Gov't files restricted if their client/s is/are or has/have been rescidivists.

jndavs's picture

Secure data?

jndavs | | Permalink

It'll just get copied to a DVD and left on a train.

Old Greying Accountant's picture

Rebecca, the answer your specific question

Old Greying Acc... | | Permalink

My personal view is NO, enrolment should be voluntary, the status quo should remain, with the option to enroll for greater privilges if desired, and certain data to be provided as part of registration.

I think the bank account required is the client account? All agents should have one, certainly those who are "qualified". If not, it would be the agents business account, if you don't want to disclose that get a client account - I see the logic in that requirement entirely. Going on Rebecca's related comment, if 100 agents all had the same designated bank account, this may high-light a tax refund "ring".

As to regulating body, that is on all our correspondence so what is the big deal? - although may be it could be a voluntary not mandatory box on the application, but as I say, HMRC can find out easily enough if they want to!

DBlood's picture

What's to discuss? Tell them to get lost until they convince us

DBlood | | Permalink

Anyone who believes it will end with enrolment must also believe in the tooth fairy.

This is the starting point - next we will have the situation of accountants being "removed" for spurious reasons.  File a couple of complaints and you will be doewn as a troublemaker and find every tax inspector and his dog hassling you. 

Welcome to the next step towards the big brother state.  Already they can access your phone records, and records of every email you send, what next - tracking cookies on your computer?  Are you sure they arent already there?  Maybe a CCTV camera over your desk ?

Astounding - the most incompetent organisation in the history of government wants to "monitor" one of the most competent professions there is.

Sorry Rebecca but I dont trust them an inch - and with good reason having today caught one of them out lying.


I am with Dblood

david wilks | | Permalink

In my mind there is no point in aiding and abetting the wishes of HMRC to try to hive off their work onto agents. I do not want total access to their records. I want to carry on my job, as I see it, to act in the best interest of my clients.

I too have had numerous "run ins" with incompetent and rude staff on the other end of the phone. They must not be allowed to get away with trying to make us all extensions of HMRC. I don't really care how their proposals are wrapped up, even in a Sunderland accent (how banal to even say that). I do not wish to "self serve" or become an HMRC policeman and I think the polls conducted to date appear to indicate there is no appetite for this.

The sooner this is knocked on the head by efficient, hardworking and credible agents the better.


chicken farmer | | Permalink

In your posting "Mission creep" you say "I am interested in the resistance to this here, when by my guess 100% of the agents at the meeting I attended saw absolutely no issue with it at all."

Perhaps you could tell us more about how this meeting was organised? Was it publicised in the local area or was it purely by invitation only? If the latter, how did the Revneue choose who to invite? If there was only a sepecially selected audience, can this really be considered a representative sample?

johnjenkins's picture

Touble is

johnjenkins | | Permalink

this is going to happen anyway. So we might as well get in on the ground level and try and vere HMRC in our direction.

They have already admitted that they do not have the staff to monitor and with even more cut backs there will be fewer "knowledgeable" staff. That's possibly why they want to give us more access.

Surely if you can go on the net and look at the information you need to get on with your job, without spending hours on the phone, (although that is what we are entitled to) that's got to be a plus.

Most agents who receive refunds for clients will already have given bank details, so where is the problem there?

So it's not really a question of trust it's a question of getting our point across from the inside instead of the sidelines.

I do feel that IFFFFFFF this works our voice will not only be heard, action will be taken.

Practicalities of self serve

Chris Wise | | Permalink

Given the various discusion, particularly about coding out underpayments and HMRC's internal guidance about not doubling tax, if an agent amends a code dwill HMRC have a right of objection? will they tell us they have objected to a code, and the grounds of the objection, or will, as now we just be left in limbo?

No client account!

Homeworker | | Permalink

I never ask for client refunds to be sent to us and so do not have, and do not wish to have, a client bank account.  I would strongly object to having to give our business bank account details on registration.  We must have the option to leave this out if we do not wish to receive client refunds.


pauljohnston | | Permalink

WE do not receive any refunds for clients.  Indeed if agents were not allowed to receive refunds how many of the CIS refund factories would survive.

If HMRC want our bank accoun so to carry out a check thats OK but I dont want to receive refunds for clients.  Ours is a profession.  We do the work and get paid by our principal (the client).

just to add....

dpeart195 | | Permalink

We do not collect client repayments from HMRC either:  it is unnecessary, unprofessional, and our clients do not expect this from us.  

ShirleyM's picture

And here's another without a client account

ShirleyM | | Permalink

We don't have one, and we don't want one.

Client Account

mpurcell | | Permalink

Here we go. People who know nothing about someone else's profession setting up 'registration' procedures. Agghhh...

I deliberately closed my client account years ago for various reasons.

Having a client account involves additional regulation and you also need to appoint an alternate if you are an ICAEW member (not necessarily a bad thing but that is not the point).

Why don't they spend their efforts trying to sort out HMRC's systems that do not work rather than suggesting how we regulate ours !

weaversmiths's picture

I am also with D Blood

weaversmiths | | Permalink

"Anyone who believes it will end with enrolment must also believe in the tooth fairy."

However this is presented to us by HMRC it is naive to assume that we will register and that will be the end of it plus it will make life easier for us.  It will not cost us to register - tomorrow is another day when all bets will be off once they have their way (which they will, of course).  They have no funds to set this list up - who is going to pay for it then (back to the tooth fairy).  It is a thoroughly wasted exercise unless it is obligatory for each and every Agent to register, otherwise just what IS the point? (Except that it obviously will be self funded by Registration Fees and Penalties).

They claim not to have a present list of agents - my Agent's Code is HK???? - how did they manage to lose that - did they leave it on a train? 

I really consider that HMRC have been extremely negligent in the past in NOT having a comprehensive list of all Agents. No wonder the country is in such a mess.



johnjenkins's picture


johnjenkins | | Permalink

clients prefer to be on 20% deduction and have their accountant receive the refund. I even have some who prefer us to hold on to it for their holiday or Christmas. It's certainly not unprofessional; it's called complying with clients requests where possible.

Anyway whether or not you have a clients' account is nothing to do with if you agree to HMRC having your bank account details on a list.

The criteria of paying by Direct Debit is handing over bank account details and to a certain extent anything can be taken out of your account by DD.

Client account

Scotton | | Permalink

No client account!

lindabuckland + pauljohnston + dpeart195 + ShirleyM + mpurcell 

Agree with you all - haven't had one in years; don't need one; and more importantly my clients would expect their money to go direct to their accounts.

Rebecca, please resist this strongly. 

Cannot see the logic for the requirement and as per mpurcell today it is yet another example of HMRC not understanding the real world that we - as opposed to they - live and work in. Maybe all HMRC management above a certain grade should have a compulsory secondment to a firm of less than say 4 partners to see how it happens at the coalface. At the present they seem to be using their interface with the Big4 as the point of reference for 'normal'.

weaversmiths's picture

No Client Account

weaversmiths | | Permalink

We do not have a client account either and do not intend to open one as we dont receive client repayments. I would object most strongly to giving HMRC my banking details - did I not see in another post just the other day that HMRC withdrew money from someone's account to 'check' a repayment they made which put the taxpayer in a fix with the bank? 

It is no good getting older if you dont get wiser.


ShirleyM's picture

HMRC & client accounts

ShirleyM | | Permalink

Quite funny really ... but I have seen a few complaints on AWeb that refunds have been paid direct to clients, even where the tax return asked for the refund to be made to the accountants client account!

I cannot remember the excuse that HMRC gave ......... but the accountants who were waiting for their fees to be paid weren't too happy!

Bank account

accountright | | Permalink

I haven't got a client bank account either! 


johnjenkins's picture


johnjenkins | | Permalink

it can happen quite innocently. If the client phones up chasing for the refund, HMRC may say would you like a cheque and of cousre the reply is yes. It has happened to us a few times.

Hopefully this is one of the areas "self-serve" will be able to deal with.


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Group: HMRC Agent Strategy
A forum for members to share ideas, evidence and common responses to HMRC's consultation paper, “Establishing the future relationship between the Tax