HMRC is currently looking at the processes for registering as an agent with a view to making longer term improvements. In the meantime, it is cleaning up its databases and seeking to remove agent codes that are no longer required or are linked to an agent firm that no longer exists.

Who needs to respond? 

At lunchtime on Friday 4 October 2024, HMRC emailed all agents who have signed up to receive HMRC agent emails. The email and the request to respond with details of their agent codes are genuine. However, only one response is required for each legal entity, ie, per sole practitioner, partnership or incorporated agent firm.  HMRC is seeking responses by 8 November 2024. After this date HMRC will contact firms that have not responded. Ultimately there is a risk of an agent code being cancelled by HMRC if there is no response. ICAEW understands that agents need to respond even if they only have one code per tax.  

What is an ‘agent code’? 

For this purpose, an agent code is the code that is issued by HMRC when an agent firm first contacts HMRC to obtain access to HMRC's self assessment (SA), corporation tax or VAT online services. The code is used to enrol for the service and may also need to be entered into commercial filing software.   

Agents will have a different code for each service. They may have several codes for each service, for example for different offices.  

In this context, agent code does not mean the agent’s government gateway user ID. Nor does it mean the agent reference number in the agent services account (ASA). The ASA is not included in this exercise.  

A firm may have codes to access other services, such as employer PAYE and Construction Industry Scheme reporting. HMRC is not currently looking at those codes, and there is no need to provide them at this stage. 

Action required 

Each firm (legal entity) is asked to identify the codes they have for SA, VAT, and corporation tax. This includes the codes for each branch, office and individual in the agent’s business.  For each code, they should determine if it:

• is in use;
• is not in use but is still needed; or
• is no longer needed.  

The firm should report this information to HMRC by 8 November 2024 by completing the online form. Only one form should be submitted per legal entity. The firm will receive an acknowledgement which they should keep for their records. HMRC will review the information and update its systems as required.  

HMRC will contact the firm if more information is needed or if the firm doesn’t complete the form by the deadline. 

ICAEW’s view 

Caroline Miskin, Senior Technical Manager, ICAEW Tax Faculty says. “This email has caused some confusion. It is not a scam, and it is important that the right person within each firm completes the form to ensure that access to online services continues without any problems. It has been sent to everyone who has signed up to receive HMRC agent emails, rather than being addressed to each agent firm.  The requirements, and what is meant by an agent code (sometimes displayed as a reference number in HMRC systems), are not as clear as they might be. This exercise may uncover some codes that are linked to legal entities that no longer exist due to firm mergers, takeovers or other changes. That might mean having to obtain fresh authority from clients in the name of the correct legal entity.”