In 2024, the government consulted on three options to strengthen the regulatory framework in the tax advice market. Autumn Budget 2025 confirms that the government will not regulate tax advisers. Instead, the government will work in partnership with the sector to raise standards. 

This includes measures that have already been announced for inclusion in the Finance Bill, namely: 

• mandatory agent registration;
• enhancing HMRC’s powers and sanctions against tax adviser facilitated non-compliance; and
• closing in on promoters of marketed tax avoidance. 

Although ICAEW supports the government’s policy objective of improving standards in the tax market and driving out the “bad actors”, it does not believe that the legislation, as currently drafted, will meet these objectives. ICAEW continues to engage with HMRC to improve the legislation. 

Frank Haskew, Head of Taxation Strategy at ICAEW said: “While ICAEW welcomes the announcement that the government will not regulate tax advisers, many will see the three measures to be included in the Finance Bill as regulation through the back door. 

“It is important also to recognise that different problems in the tax advice market need different solutions. The measures so far are about sanctioning poor behaviour, but this needs to be balanced by incentives to encourage improvement and raise standards.”