Last week the Government also announced three technical consultations on draft legislation. More details are set out below.
Raising standards project
Following the package of measures announced at the Autumn 2024 Budget, on L-day HMRC also published two separate technical consultations, together with draft legislation.
Overall, the measures are designed “to deter harmful practices, hold advisers accountable, and promote a more transparent and trusted tax advice market” and have the objective of supporting the Government’s three main priorities: to close the tax gap, enhance services, and modernise the tax system.
Both these consultations will run for eight weeks and will close on Monday 15 September. More details of the key proposals are set out below.
Modernising and mandating tax adviser registration
This consultation seeks views on the introduction of mandatory registration for tax advisers engaging with HMRC on behalf of clients, to ensure they meet minimum standards.
Registration will be required from April 2026 and is supported by a £36 million investment in modernising HMRC’s adviser registration services.
Enhancing HMRC’s powers and sanctions against tax adviser facilitated non-compliance
This consultation seeks views on further measures to ‘support compliance and transparency in the tax advice market’. Proposals include strengthening HMRC’s powers to:
- Access information from advisers suspected of facilitating non-compliance,
- Apply proportionate penalties where there is evidence of such behaviour, and
- Publish details of advisers subject to HMRC sanctions.
HMRC also published a summary of responses on this measure, in response to the recent consultation in this space.
Views on the draft legislative clauses and the practical implications of the proposed measures are sought by email to raisingstandardsconsultation@hmrc.gov.uk.
Making Tax Digital (MTD) and Penalty Reform – draft legislation for technical consultation
Last week, the Government also published draft legislation for Making Tax Digital for income tax and penalty reform.
This aims to refine and simplify the existing framework and legislates for the changes announced in March at the Spring Statement. This includes:
- A deferral from MTD until at least 2029 for some groups, such as Ministers of Religion, Lloyds Underwriters, and recipients of the blind person’s allowance,
- Exemptions from MTD for others, including individuals with power of attorney, and non-UK resident entertainers with no other qualifying income,
- Technical and policy amendments, including the authority for HMRC to cancel or reset late submission penalty points and cancel associated financial penalties,
- A requirement for MTD users to submit their end of year tax return using MTD-compatible software, and
- A new qualifying income threshold for MTD for Income Tax of £20,000 to apply from 2028/29.
As also mentioned at the Spring Statement, individuals will not be required to use MTD until April 2027 if they have information that they would need to submit using the SA109 supplementary pages. HMRC will work with stakeholders to finalise this deferral, which will be included in legislation later this year.
In line with the existing tax policy framework, the aim of this technical consultation is to seek views on whether the draft legislation works as intended. To provide comments, please email: makingtaxdigitalconsultations@hmrc.gov.uk by 16 September 2025.
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