HMRC’s online services terms and conditions states that agents should “never ask” their clients to share their credentials with them, and that failure to follow this guidance will mean that the agent is considered in breach of HMRC’s standard for agents.

Where HMRC finds that an agent’s behaviour has fallen below HMRC’s standard for agents, HMRC may suspend the agent’s tax adviser registration. The consequences of this for the agent are explained in a separate article.   

Research published in 2023 on agents’ experiences of HMRC’s digital services found that 58% of agents participating in the research had logged into their clients’ online accounts at least occasionally. The research suggested this may have been an indication that HMRC’s digital services for agents were not sufficient to meet agents’ needs to access client data.  

ICAEW has pressed HMRC for improvements to its services for agents and continues to do so. In July 2025, HMRC set out its plans to develop and deliver improved services for agents. This is considered in detail in an earlier article. 

Helpsheet A provides guidance on the application of the Professional Conduct in Relation to Taxation (PCRT) fundamental principles and standards for tax planning when dealing with the day-to-day work of filing tax information and completing tax filings. It says that: “Except in exceptional circumstances, a member will explicitly file in their capacity as agent” and that members are advised to “avoid knowing or using the client’s personal access credentials”.