Enrolment - why, who and how?

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Rebecca Benneyworth
Rebecca Benneyworth Training Consultants
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Rebecca Benneyworth provides an in-depth description of the enrolment proposal in the HMRC consultation document on Agent Strategy. Her comments are drawn from a study of the document and information provided at a meeting with Mike Clasper and Brian Redford, attended by a group of agents who were not affiliated to a professional body.

One of the three main aspects of the new HMRC strategy is enrolment for the professional agent. Although some other agents (such as the voluntary organisations) will also enrol under the proposals, the broad intention is that a new “clean” database of paid tax agents who are in business will be created.


Perhaps surprisingly HMRC do not already have much of the information that it is suggested that you p...

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20th Jun 2011 08:32

Short responses to enrolment questions


These are the quick responses I had jotted down for the reply to HMRC on enrolment

1.      All agents who wish to use online services should provide data set with self service as an additional option.

2.      Office specific logins, one registration irrespective of the number of offices.

3.      Exclude bank account and professional body from the data set but include size of firm (employee numbers).

4.      Money laundering registration number, VAT registration number, Data Protection registration number and proof of Public Liability Insurance.

5.      Agents currently registered should have a year to add the additional information.

6.      Not practical to monitor – will have to trust agents to update as necessary.

I do not believe we should declare a professional body as any one firm may contain a constantly varying mix of qualified and non-qualified staff.  

I do not believe that performance should ever be judged by HMRC for any reason.

I would like to think that this collation of information about us will work towards establishing nationally a reputation in the same way we used to with individual offices.  

Do these make sense?

-- Marion

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20th Jun 2011 09:37

Thanks so much Marion.

Your comments are very useful.

There is a debate already raging on the detail in the discussion group for those who want to engage!

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By txcjg
22nd Jun 2011 12:55

Agent Registration HMRC Information Held.

I find it suprising HMRC do not hold the info on professional agents not a member of a professional body.

Surely the HMRC MLR registration at Southend covers this category of agent who must be registered under MLR 2007. Also going forward the HMRC MLR registration of professional agents not a member of a professional body should be combined with what ever the new proposals are inacted. Most of the information listed is included in the 10 page HMRC MLR100 for MLR registration.

Perhaps HMRC have not realised they hold this information as all the paperwork they send out including the MLR 103 Certificate of Registration (current issued Oct 2010) for MLR is on HM Customs and Excise letterhead!

As an ex Inspector of Taxes I understand something needs to be done as I have seen some poor agents both qualified and unqualified. However most of us do a good professional job which helps both the client and HMRC.


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22nd Jun 2011 14:09

Firm vs individual

As a sole practitioner it makes no difference to me but MLR/PII/data protection/practicing certificate are all done by firm.

The firm must decide which professional body issues the practising certificate (or not) which may not be the same as the qualifications of some of the principals.


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By louiseg
22nd Jun 2011 17:55

Why, Who, When

I agree that the following should be added as essential information

Confirmation that they are registered (or otherwise regulated) for money laundering purposesConfirmation that they are registered for data protection purposesConfirmation that they hold professional indemnity insurance

I also agree with Chris' comments that HMRC should actually have some of this information already BUT they are not great at communicating across departments so maybe a clean sweep is a good way of sorting this out. 


As to your specific questions Rebecca:

It should apply to ALL tax agents, multi office firms will have to come up with something that works for them, the data set is reasonable (provided HMRC can assure us all on data protection).  When should they do this - well January is usually a quiet month isn't it (said with a wry smile)

Presumably this can be done through an online enrolment process and agents should be capable of updating information as and when they need to.  There shouldn't really be any need to re-enrol annually - this would just be an unnecessary burden.




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22nd Jun 2011 21:23


Please do not include VAT registration, as not all paid agents are large enough to be VAT registered!  Otherwise, I think I will go along with Marion.

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By Arm266
23rd Jun 2011 12:32

HMRC Agent Strategy

I would like to comment on the suggested annual re-enrolment from past experience of the current system.

I tend to retain clients on my list for several years after HMRC have ceased to require them to complete an SA100 return [due to cessation of income which has to be reported].  This is in case HMRC enquire into their cases at a later date; I have had two clients where HMRC did not get around to instigating the enquiry until over 2 years later.  If I had deleted them, then I would have had to go through the whole process of enroling them again and probably wouldn't have been able to act for them by the required reply date.

However, if there has to be an annual re-enrolment, would I be able, or wish to, enrol such dormant clients?

Also would there be an ability to import existing registrations into the re-enrolment or would agents then have the lengthy task of re-inserting ongoing clients.  Indeed, would agents know which clients were ongoing if, as my contract states, there is no commitment by the client to future years.  I rely on the client being totally satisfied with my work and re-appointing me in successive years.

I would be grateful for other agents experiences/views.

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By jeep
23rd Jun 2011 16:49

agent enrolement

I am not sure why some are suggesting that the data set supplied at registration needs to contain information about MLR registration, VAT registration, etc.  This suggests that the registration process is being view as a mechanism to be used by HMRC to police the competence of agents.  Competence being measured by the disclosure of these details. I do not think that HMRC is up to that task nor do I think that registering under MLR or registering for VAT etc provides any evidence of the agents competence.

If as you say Rebecca the registration is to provide HMRC with a list of 'trusted agents' and by that they mean agents who represent their clients for a fee, the data set should contain information about number of clients for whom the agent acts split perhaps between PAYE, SA, VAT etc.

I do not think that the data set chould contain bank details, we all know how reliable HMRC are in keeping data safe.

So my suggested data set would contain:

1 Agents identity (the firm not individuals where it is a partnership or Ltd.)

2. Business contact details, address, telephone number. e-mail address and I would suggest a central contact point for firms who have multiple offices.

3 Relevant HMRC agent identifier numbers with a note of client numbers represented under each service.  This would not be a list of clients but mearly the number of clients, which may be banded into groups 0-20, 21-100, 101-500 ect.

Anything else is surperflous to the stated use of the database.

I hope this is useful.


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27th Jun 2011 09:38

You said "This suggests that the registration process is being view as a mechanism to be used by HMRC to police the competence of agents. "

Exactly!!! This is what I have been saying all along. It has nothing to do with self serve - thats just a smokescreen. It has everything to do with state regulation

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27th Jun 2011 11:32

enrolment as registered agents

In principle this sounds good. We can surely not object to HMRC wanting to know who it is dealing with and making sure its systems are secure. To be frank if this proposal improves the current CAAT system and means that agents get an improved service then I guess I approve.

BUT - how long before this is another thing we have to pay for? We already have to register and pay professional fees, data protection fees, money laundering fees, insurances ad-infinitum, etc. etc. So long as there is no charge and no complex and costly monitoring process then I guess this is inevitable but if we have to pay for the privelege then this is not on!

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27th Jun 2011 11:48

Have they lost another d-base?

I've had my agent code for many years - they know who I am. Or should do...

Now; either their d-base skills are extremely poor, or another one's gone up in a puff of logic.

Something just ain't right...







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27th Jun 2011 12:16

imprimatur St. James Place Tax Guide

Surprised that you allow your website, intended for unbiased independent advisers to effectively endorse a company which many see as deliberately exploiting the grey area between independent and tied.

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27th Jun 2011 12:33

confirmation they have met relevant tax obligations - what is t



how is this anything to do with this topic?, and rebecca makes no comment at all.

"and confirmation that they have met their relevant tax obligations to file returns and meet liabilities "

why is it 100% of dealings with HMRC are sinister? who thought it was a great idea to put this in ?

- it is the same as being forced to lie when filing CIS returns for clients. i would like to always be able to be honest with HMRC. - i am fed up they force me to lie over 64-8 status thanks to their pathetic record-keeping etc.... zzzz








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27th Jun 2011 12:44

data set extents




i think the initial data gathering to set up the list of "newly enrolled" should be the bare minimum to get going.

in year 2 etc, they could add in some more fields once they have a defined set of customers to talk to about it. --> why consult the whole of uk about something that only applies to a few thousand etc..... carts, horses,  re-arrange etc.

there should definitely be an "entity identification field" = co reg no, llp numb, sole-trader, partnerhsip etc..

And a SENSIBLE procedure to follow when this field changes - not what the muppets did to me recently.

Each practice should nominate the person managing the account, so they can also maybe allocate branch offices via their main regn, with sub-codes?

oh and for goodness sake set up a central office to manage this 'relationship' so we know WHO the heck to talk to, at moment it is sooooo stressful as to be pointless trying to find an "agent-maintainer"




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27th Jun 2011 13:10

Seems positive but some comments leave a bit to be desired.

I do not like the query re "having met their tax obligations". Considering the amount of disputes we have to sort out with HMRC re tax obligations I can see an agent running foul with his own stuff and then what. Not allowed to carry on as an agent? Forced to concede to carry on for clients? It gives a stick to HMRC which is bad news. Revenue has plenty ammo for recaltent tax payers to need this.

One other commentator says no professional body to be given but then we must give lots of intrusive data to register. Data the Institute has anyway. A member of good standing should not be required to give anything other than his Institute. HMRC can always lodge a complaint with the Institute if warranted.

It is obvious some practitioners would like some of the competition to be removed using this, but that is not what it is about. Some seem to also envy members of registered bodies. Lets not use this to grind axes.

I like registration if it gives me better access to HMRC and better support. Neither exist at present. Current agent registration gives very limited benefits other than ability to e-file on behalf of clients.


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By Red1960
27th Jun 2011 13:13

Not happy with this at all.

Every time HMRC put their case forward they say they only want minimal information and that they do not want to discriminate between agents and by implication the tax payers they act for. They are also talking about security and I’m happy to assist in that regard.

Fair enough, but then I have to ask why more information is needed than is absolutely necessary to perform these simple tasks. Of what relevance are the following:

P.I. details.Membership of professional bodiesUTR to ensure the agent is up to date with their taxes.Data protection registration (not that I am against this but simply put of what concern is that to HMRC)MLR registration - they already have this

Why is it necessary to distinguish between agents who are in business on their own account and those who act in an unpaid capacity (or for voluntary bodies or not)?

The problem is that HMRC might be saying that they do not intend or want to create a two or even three tier system which discriminates against certain agents (and their clients) on an arbitrary basis and which is quite possibly a restraint upon trade but if that’s case then why do they need precisely the information required to do just that rather than the very basic information needed to create a secure register?

Why isn’t anyone asking that question?

If it’s their intention to ensure that tax agents are thoroughly regulated and regularly inspected ,by them at some undisclosed point in the future, then why don’t they have the honesty and integrity to say so now?

Because they would rather do it quietly by the back door while nobody is watching.

We already know exactly what the top tier at HMRC think about agents and quality of work which now seems to provide them with a scapegoat for their own failings and justification for regulation at some stage… once they have the basic system for that in place.

Could it be that the databases they have designed themselves are unfit for purpose and they need our cooperation (and free labour) to create this new database for them at minimal cost? Could it be that if agents knew exactly what the real agenda is they wouldn’t touch it with a barge pole?

Hell, why not go the whole way and let’s have HMRC set their own competence examinations as a requirement to practice and ditch the professional bodies entirely?

Thin end of the wedge and we have to make a stand against this now otherwise we will come to regret it.

This whole security angle is a red herring because it’s not necessary to create a tiered system for it to be secure and that is the real point which should be pressed to them. If they want to check my security I’ll take my passport/driving licence to the nearest office for verification because that is all they need.

I’m happy to provide them with the following but no more because that is all they need:

• Name
• Business Address
• Telephone number
• Business Email address
• details of a designated bank account for the receipt of repayments on behalf of clients (if applicable)
• details of the business owner(s)/principals

The price of freedom IS eternal vigilance: if they don’t want regulation and a discriminatory system let’s not give them the tools to create one.

How does the Revenue identify “reputable agents” if not by experience through the course and conduct of their relations with them?

That is what everyone else does at the end of the day and that is what they can and should be doing.



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27th Jun 2011 15:11


I have tried, as far as possible to encourage debate between members by providing as much explanation as I am able about what is in the consultation document and what I have been told in public by HMRC. I therefore did not seek to make comment on the "providing your own tax information so that we can check up on you" data element.

The chair (if you'll forgive my self appointed role) does not tell the meeting what to think - if working properly they should encourage comment and debate. I try to confine my comments to correcting those who state their opinion as fact so that other members reading the thread are not distracted from the debate. I also respond when my own credibility is called into question. You will see that in the discussion group I tried to draw out members' comments on precisely this issue, and have had some slight success there.

I need a broad sweep of views from members to pull together a consultation response; of course one of my problems on any forum like this is that there are a few who shout loudly, and the remainder are content to watch - indeed as one member who contacted me privately said - I'm not prepared to comment on the site for fear of the response I will get. I guess if your views are very strongly held then you will take the time to express them - whether on here or elsewhere.

That said, this has been an interesting debate, but I would re-iterate that my job is to ask members to comment, not to hold forth on my own views.

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By lme
27th Jun 2011 16:08


Thank you for this constructive article which is particularly welcome when the default positon of some senior members of our profession seems to be antipathy towards anything HMRC say or do.

A few thoughts:

may be helpful to have professional body on the database so that HMRC can engage with those bodies (and directly) knowing what kind of proportion of agents are representedshouldn't ask for more detail than is really necessary - assuming a large number of agents are represented by a professional body with PI and MLR requirements, should not be repeated by HMRC - or perhaps those details only for those who don't have this kind of professional oversightenrolment should be on line, possibly also paper, say over 12 months then everyone should be caught in their annual cyclere-enrolment sounds heavy - perhaps an annual email reminder to update your details for any changes, this should be at agent and not at client level

-- Lydia

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By geoffmw
27th Jun 2011 16:55

some agents

may simply be a family member with a lasting power of attorney.

Such a person must be in a position to use the system.

How does that square with the consultation document?

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By Bluffer
27th Jun 2011 16:57


You article deals with enrolment and I don't want to moan about other aspects at this point, but it is what comes after enrolment that concerns me and how soon after enrolment.

Consider your paragraph headed "Who?" please:

"....the meeting I attended made it quite clear that for the initial enrolment, all of those currently practising in tax as a paid agent would be entitled to enrol on the “professional agents” database.". How de we view the use of the word "initial"? Presumably it means that after the initial enrolment, NOT all of those currently practising in tax as a paid agent would be entitled to remain enrolled?
 At the said initial enrolment, how will HMRC know who is a "paid agent"? If you study the data set suggested in the Condoc, only the last item will provide conclusive information as to who is a paid agent. So is HMRC going to insist on this irrespective of what we are prepared to provide?
 "HMRC has no intention to discriminate at this point...". Does this mean that HMRC intends to discriminate at some later point?


I then refer to the bullet points concerning agent engagement on page 30 of the Condoc. These points (and possibly others) will hit after initial enrolment: Client/Agent performance indicators; Formal Qualification(?);  "Bookkeeper" not able to Self-Serve(?); HMRC refusing to deal with agents.

The profession is being consulted, but all of these things could be forced on us very soon after "initial enrolment".

I'm afraid that I don't trust HMRC to handle the Agent View and we should be very careful about what information has to be provided for enrolment.


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27th Jun 2011 17:14

Thanks Bluffer

Hoping I can clarify a little here.

Reading between the lines of the consultation document, I think it is HMRC's medium term desire to have all tax agents either a member of, or under the umbrella of, some sort of representative body. This would allow the "report to your regulatory body" bit to work for all agents rather than just for those who are members of bodies. However, HMRC cannot impose qualification by examination as it is against HR law - to deprive those currently in business from being able to make a living. I guess they are hoping that the professional bodies will stick their collective (or indeed individual) heads above the parapet and say they will undertake to "supervise" non members. I really don't think the prof bodies will have an appetite for that as it could be expensive and detract from their current role in relation to full members who have passed exams to join (and who pay subs).

What I therefore anticipate is that HMRC might set a sunset clause to say - 1. everyone who joins after this date will have to be a member of a body, and/or possibly 2. everyone already on the list must be a member of a body by another date (probably a 10 year window or similar). Hence my hedging about in my descriptions. I hope this is clearer.

However, on the face of it they are asking whether as a group tax agents think that everyone should be a member of a body - in this they know that the vast majority are members of bodies (70% of agents) so they will get a potentially skewed response to that - hence, (again my suspicion) the massive effort to engage with those agents who are not members of bodies to gather their views (which wraps in the meeting I went to). I do think they will take the views expressed into account but they want a self regulated profession and this is difficult to achieve if they don't want to be the regulator, but there is a bunch of potentially unregulated agents.

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27th Jun 2011 17:26

your other points

A couple of other of your questions go into the "Agent view" and the really knotty issues like chucking people off the list. I'm writing a similar piece on that, but have got bogged down with paying work at the moment, so I'll get it up on the site in the next day or so.


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28th Jun 2011 00:24

Agents Time for a proper LEGAL definition

I can imagine many soothing pints being sunk by the huge army of 'agents' out there who get away with quite incredible tax avoidances and other shady dealings.     The maligned HMRC would do the COUNTRY a great favour if it REALLY bit this bullet and made it a legal condition of being an agent that such a person or firm should conduct itself in a proper manner - like a solicitor/accountant/co.director.

I am personally aware of such folk who flit in and out of 'agency' as necessary to cover tax sins and other devilish cons to suit themselves and their buddies.   The army of 'em must be laughing all the way to the mattress or box of gold in the garden.     The huge 'barter' economy just revels in such glorious slackness on the part of HMRC. ALL legit agents are safe.     It is time to take (a) a lead and (b) strong measures.   'Enrol' must cause great gusts of laughter in the pubs and clubs of villainy:   "'Ere Bert..?  You registered for money laundering yet..?  I've got 30 grand waiting for the cleaners...!"



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28th Jun 2011 16:18

multi-jurisdictional as well as multi-office

The larger firms increasingly use overseas locations as well as UK locations, so any registering process needs to take this into account as well as considering the issues of transmitting data between different jurisdictions. If some body was wanted to enrol all agents then it would need to ensure that those situated outside of UK waters also come within it or are not allowed in, in the first place.

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28th Jun 2011 16:33


I would have agreed with you 30 years ago, even 20, but not now. Yes there are people out there "doin the business" but few and far between and they have clever dicky accountant and solicitors backing them up.

This isn't about them cos they ain't gonna be caught by silly HMRC compliance rules. This is about a normal agent trying to earn a living without being burdoned by beaurocratic nonsense so HMRC perhaps might catch an Accountant bartering with a car mechanic. (yes I know Accountants fees would have to be high to barter with a car mechanic)

If a workforce has a few perks they are happier, work harder and produce more. Take that away and you get stagnation, a bit like what HMRC are experiencing now.

I remember a few years ago the SFO lost a few high profile cases which cost the tax payers a few bob. Ever since then the SME's have been hit time and time again. 

I cannot see any kind of control at any time working, neither can I see the need for it.

Just a simple question put to all agents (not bodies), Rebecca. Do Agents Q or QBE see a REAL NEED  for any more control? If the answer is yes, then we have a REAL problem in our profession.

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By drwebb
01st Jul 2011 14:46

HMRC Consultation Document

It is my understanding that the reason HMRC wish to have much of the information is that they are to give trusted agents the ability to make changes to information on their website, including, for example, PAYE codes.  They do not want to give everyone that ability, but only ones they can trust to act in a professional manner.  They have been subject to a number of scam attempts, mostly based overseas, and do not want to give these type of organised crime organisations the opportunity to change the information on the website.

I believe therefore that they would like all agents to be regulated by a professional body, so that they can get that body to ensure that they are acting professionally.  The bank account details are to ensure repayments are only paid into properly controlled UK bank accounts, not the account of some criminal organisation overseas.

If I was allowing anyone to change information on our website, I would want control over who I allowed to do it, and I am pleased HMRC are taking what I bellieve to be a responsible attitude in protecting what is, in reality, our money.  I believe that agents in general should not have their current powers reduced, at least without proper discussion and agreement, but I similarly believe that additional powers should only be given to agents who HMRC are convinced are bona fide and properly registered.

Incidently, I was told that HMRC have only refused to deal with 2 agents in the last 10 years, the one currently in the news and one when he was imprisoned for the second time for fraud.  I do not think this is being over zealous with their power.

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03rd Jul 2011 14:43

Bone fidi

agents are already registered. Either with their bodies or customs (MLR). Even having details of a bank account would not stop a "dodgy" bank account being put on a tax return for a refund.

I stick to my original post "great idea but too many strings".


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