Over the next few weeks, we’ll be taking a look at the key changes to UK tax legislation which take effect due to the commencement of either the new Financial Year 2026 from later this week on 1 April 2026 or the new tax year 2026/27 which starts next week on 6 April 2026. Part 1 of the series focuses on Making Tax Digital (MTD) for Income Tax and measures affecting tax agents.
MTD for Income Tax
6 April 2026 marks the go live mandatory start date of MTD for Income Tax. Mandation commences from this date for self-employed individuals and landlords with qualifying gross income (not profit) which exceeded £50,000 in the 2024/25 tax year. The mandation limit subsequently falls from 6 April 2027 to £30,000, and then to £20,000 from 6 April 2028.
MTD requires those mandated to keep digital records and submit quarterly summaries of income and expenses to HMRC via compatible software. The first deadline for submitting MTD 2026/27 quarterly updates for quarter 1, which for most mandated taxpayers will run from 6 April 2026 to 5 July 2026, is 7 August 2027. Members can access the Institute’s MTD hub for support on this key change.
Ahead of the start date, HMRC has published breakdowns by industrial sector and geographic region of the taxpayers expected to be within scope of MTD for Income Tax from April 2026. The data is based on information from 2023/24 Self-Assessment returns.
Last week on 24 March 2026 the Government laid the final regulations in Parliament on the requirements and scope of MTD for Income Tax. The regulations were laid after further amendments based on feedback from stakeholders, including Chartered Accountants Ireland.
Key aspects of the regulations include the phased introduction of MTD for Income Tax based on income, including those with qualifying income over £30,000 from April 2027 and those over £20,000 from April 2028, the requirement to keep digital records and submit quarterly updates, and annual returns through MTD-compatible software. The regulations also offer practical features, such as the option to align reporting to calendar quarters and targeted exemptions for those for whom digital use would not be reasonably practicable.
A new Tax Information and Impact note (TIIN) on the £20,000 to £30,000 mandation cohort that will be joining MTD for Income Tax from April 2028 has also been published to supplement the TIIN published in 2024 for those with qualifying income above £30,000. The TIIN sets out the Government’s view on the taxpayer impact of MTD for Income Tax, including the cost to transition to and operate new software to comply. According to HMRC, although this is broadly comparable to those with qualifying income in excess of £30,000, the new TIIN reflects a different demographic, and revised ‘assumptions’ that underpin the estimated software costs, agents’ costs, training, and familiarisation time and free software take-up.
Measures affecting the tax adviser market
From 6 April 2026 HMRC will have a range of enhanced powers to sanction tax advisers, in addition to new powers to tackle promoters of tax avoidance arrangements. Broadly, for the latter, there will be a statutory ban on promoting tax planning arrangements with ‘no realistic prospect of success.’ Regulations also will prohibit the promotion of arrangements ‘likely to cause harm to participants.’ The sanctions under this legislation will be severe and include significant penalties, a strict liability criminal offence, and the ability of HMRC to suspend an agent’s registration.
Legislation will also take effect from 6 April 2026 which will amend the tax agent ‘dishonest conduct’ rules introduced by Finance Act 2012. Essentially, dishonest conduct will be downgraded and the rules will apply to tax advisers who facilitate non-compliance by their client. The associated penalty framework will also be substantially enhanced and will also require HMRC to publish information about any adviser charged a penalty exceeding £7,500.
From May 2026 new rules will also require those providing tax advice, including overseas advisers, to mandatorily register with HMRC. Readers may recall that the timetable for registration was published last month.
By way of reminder, registration is expected to officially open online from 18 May 2026. Importantly, if an agent already has an agent services account (ASA), the agent does not need to register again. Instead, HMRC will subsequently contact the agent via its ASA when more information is required in order to check that the agent meets certain conditions.
Agents who do not have an ASA and who meet the conditions to register will need to register for an ASA from 18 May 2026, unless one of the following applies:
- if the agent already has a Self-Assessment or Corporation Tax account, registration is required from 18 August 2026, and
- if the agent only provides third-party payroll services on behalf of clients and does not interact with HMRC in any other way, registration is required from 18 November 2026.
Note that irrespective of the registration date which applies, a transition period of at least three months is available.
The legislation implementing this is contained in Finance Act 2026. According to statements made by government ministers in the House of Commons, whilst the draft legislation moved through the Parliamentary process, the measures which will directly affect tax agents, including mandatory registration, are expected to be implemented in a reasonable and proportionate manner.
Dan Tomlinson MP, Exchequer Secretary to the Treasury (XST) specifically addressed comments on the draft legislation to the House of Commons during its scrutiny of the Finance Bill in early February 2026 which acknowledged engagement on these issues by the Professional Bodies, which includes Chartered Accountants Ireland, and the important role that agents play in the tax system.
At column 223 the XST said “I have been engaging in detail with stakeholders on the changes we are making, because it is important that legitimate and good tax advisers see that the Government have confidence in them and the work they are doing”. He went on to say that agent registration is “specifically about stopping harmful tax advisers who do not meet the basic minimum standards” and that it does “not give HMRC new powers to investigate whether applicants breach the standard for agents”.
On HMRC’s powers to suspend an agent’s registration, the XST said at column 224 that HMRC will:
- “suspend a tax adviser only after due process, including offering opportunities to comply and a chance for the adviser to explain whether there is a good reason why they are unable to do so”, and
- “not use these powers for minor breaches”.
At column 230 the XST further said that HMRC will “always work with a tax adviser who is genuinely trying to comply, will never suspend a tax adviser when doing so would be unreasonable or disproportionate, and will always consider the nature of any potential breach and how a suspension would impact the tax adviser and their clients”.
On sanctionable conduct, at column 235 the XST said that “the powers will not affect advisers who act in good faith, or who take a credible view as to what the law requires of their clients, including where they use extra-statutory concessions or HMRC guidance to form that view”. Furthermore, the measures “do not affect advisers who make mistakes while trying, as the vast majority do, to do the right thing”.
The XST’s comments were echoed by Lucy Rigby MP, Economic Secretary to the Treasury (EST), when speaking about the prohibition on promotion. The EST confirmed at column 204 that the powers “are not intended to be directed against legitimate tax advisers who are operating to a high professional standard but, while acting in good faith, make genuine mistakes” and that ministers have “asked HMRC officials to work with stakeholders in developing published guidance to address the fine detail of exactly how the prohibition will work in practice”.
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