The Finance Bill
Finance (No. 2) Bill 2024-26
Text of the of the Bill as introduced on 3 December 2025, accompanied by explanatory notes, subsequent versions, amendment papers, and record of its progress through parliament.
Finance Bill 2025–26 — draft legislation and technical tax documents
Collection of draft legislation and tax information and impact notes (TIINs) for the Finance Bill 2025-26.
Implications for tax advisers
ICAEW has expressed serious concerns with the package of measures in the Finance Bill 2025-26 affecting agents and has called for significant changes to be made to avoid the risk of harm to taxpayers and mainstream firms.
Legislation included in the Finance Bill 2025-26:
- requires tax advisers interacting with HMRC to register with HMRC. HMRC may refuse or suspend registration where there are concerns about the firm’s conduct (cl220-246, Sch 19 and 20);
- extends the tax agent dishonest conduct regime by lowering the threshold for sanctions to “doing something with the intention of bringing about a loss of tax revenue” (cl247-250, Sch 21); and
- introduces a new strict liability criminal offence for promoting arrangements that have no reasonable prospect of success (cl156-162).
Latest tax news
Timeline of drafts and ICAEW representations
Draft Finance Bill 2025-26 and ICAEW responses
Draft legislation published for Finance Bill 2025-26
21 July 2025, HMRC
Draft legislation, supporting documents and tax information and impact notes (TIINs) covering proposed measures on Income Tax, Corporation Tax, Inheritance Tax, and more.
ICAEW REP 62/25: Draft Finance Bill: changes to charity compliance measures
27 August 2025, ICAEW
ICAEW representation responding to the 'Changes to charity compliance measures' draft Finance Bill legislation published by HMRC on 21 July 2025. It argues that some of the proposed amendments risk creating uncertainty and unintended tax consequences for charities, and recommends revisions to ensure clarity, fairness, and alignment with existing tax principles.
ICAEW REP 65/25: Making Tax Digital draft legislation and regulations
12 September 2025, ICAEW
ICAEW representation on the Making Tax Digital draft legislation published by HMRC on 21 July 2025. It reiterates ICAEW's opposition to mandatory quarterly updates, citing added complexity and cost. It recommends keeping annual reporting (making quarterly updates optional), and urges clearer exemptions and better support for taxpayers to ensure the regime is practical and proportionate.
ICAEW REP 66/25: Land remediation relief consultation
15 September 2025, ICAEW
ICAEW representation responding to the Land Remediation Relief consultation published by HM Treasury on 21 July 2025. It makes a number of suggestions for improving the relief (reform of restrictive conditions such as the fixed dereliction date, for example), and recommends clearer HMRC guidance.
ICAEW REP 67/25: Reforming inheritance tax - unused pension funds and death benefits
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on reforming inheritance tax for unused pension funds and death benefits published by HMRC on 21 July 2025. It urges revisions to address administrative challenges and unintended consequences. In particular, it argues that the government must implement a system where pension scheme administrators (PSAs) are required to make a fixed deduction of IHT from pension funds.
ICAEW REP 68/25: Draft Finance Bill 2025/26 legislation: reforms to agricultural and business property reliefs
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on reforms to agricultural and business property reliefs published by HMRC on 21 July 2025. It expresses disappointment that key concerns — such as the lack of transferability between spouses and the practical challenges estates will face in funding new inheritance tax liabilities — have not been addressed. ICAEW urges further revisions to ensure fairness, viability for businesses and farms, and alignment with established tax principles.
ICAEW REP 69/25: Modernising and mandating tax adviser registration with HMRC
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on modernising and mandating tax adviser registration with HMRC, published on 21 July 2025. It recommends further consultation and revisions to ensure the legislation is practical, proportionate, and supports high standards in tax advice.
ICAEW REP 70/25: Enhancing HMRC’s powers: tackling tax adviser facilitated non-compliance
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on enhancing HMRC’s powers to tackle tax adviser facilitated non-compliance published by HMRC on 21 July 2025. It recommends revisions to ensure the legislation is proportionate, clearly focused on deliberate misconduct, and aligned with established tax principles.
ICAEW REP 71/25: Proposals to close in on promoters of marketed tax avoidance
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on proposals to close in on promoters of marketed tax avoidance published by HMRC on 21 July 2025. It recommends narrowing the scope of criminal offences, clearer definitions, and further consultation to ensure the legislation is targeted, fair, and aligned with established tax principles.
ICAEW REP 72/25: Better use of new and improved third-party data to make it easier to pay tax right first time
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on better use of new and improved third-party data to make it easier to pay tax right first time, published by HMRC on 21 July 2025. It endorses a number of provisions (such as the move to quarterly reporting), but raises certain concerns, for instance around the use of penalties for failure to notify.
ICAEW REP 73/25: Draft Finance Bill 2025/26 legislation: employee car ownership schemes
15 September 2025, ICAEW
ICAEW representation responding to the draft legislation on Employee Car Ownership Schemes (ECOS) published by HMRC on 21 July 2025. It raises concerns that the proposed changes could unintentionally bring genuine commercial arrangements into benefit-in-kind charges for employees of car manufacturers, and recommends consideration of transitional provisions.
Tax returns and Finance Bill concerns
1 October 2025, ICAEW
Episode of The Tax Track podcast explaining the Tax Faculty's concerns with draft legislation for Finance Bill 2025/26 that promises to make significant changes to the tax system, particularly for agents.
ICAEW REP 82/25: Finance Bill Sub-Committee - call for evidence on draft Finance Bill clauses for reforming inheritance tax
7 October 2025, ICAEW
ICAEW representation giving evidence on the Draft Finance Bill 2025-26 to the House of Lords Economic Affairs Finance Bill Sub-Committee. It focuses on two IHT-related measures included in the draft Bill, outlining issues which might arise from their implementation, and urging clearer rules, transitional measures, and better government support.
Autumn Budget 2025
Budget 2025
The Chancellor of the Exchequer presented her Autumn Budget 2025 to Parliament on Wednesday 26 November 2025.
ICAEW hub: Autumn Budget 2025
See ICAEW's analysis of key announcements and news.
Finance Bill 2025–26 and ICAEW responses
Finance (No. 2) Bill 2024-26
Published on 4 December 2025.
TAXguide 05/25: Finance Bill 2025-26
12 December 2025, ICAEW
ICAEW’s Tax Faculty provides an overview of the key provisions of Finance Bill 2025-26, including commencement dates and links to further information.
ICAEW REP 04/26: Finance Bill 2025-26, Clause 62 and Schedule 12 — Inheritance Tax — Agricultural Property Relief and Business Property Relief
8 January 2026, ICAEW
ICAEW representation urging the government to use the Finance Bill process to resolve the remaining uncertainties with regard to the proposed reforms to agricultural property relief (APR) and business property relief (BPR).
ICAEW REP 05/26: Finance Bill 2025-26, Clauses 63-68 — Inheritance Tax — pension interests
8 January 2026, ICAEW
ICAEW representation putting forward suggestions as to how the charging of IHT on unused pension pots from 6 April 2027 might be better implemented.
ICAEW REP 10/26: Finance Bill 2025-26, Clauses 247–250 and Schedule 21 — Conduct of tax advisers
28 January 2026, ICAEW
Written submission to MPs from the ICAEW Tax Faculty, regarding the proposed extension of the tax agent dishonest conduct regime in Sch 38, FA 2012.
ICAEW REP 11/26: Finance Bill 2025-26, Clauses 220–246 and Schedules 19 & 20 — Registration of tax advisers
28 January 2026, ICAEW
Written submission to MPs from the ICAEW Tax Faculty, regarding the planned introduction of a new requirement for all tax advisers to register with HMRC if they wish to interact with HMRC on behalf of a client, unless a limited exception applies.
ICAEW REP 12/26: Finance Bill 2025-26, Clauses 156–162 — Prohibition of promotion of certain tax avoidance arrangements
28 January 2026, ICAEW
Written submission to MPs from the ICAEW Tax Faculty, outlining its concerns and recommendations with regard to the new measure to prohibit promotion of tax avoidance schemes.
Briefing for MPs — Clauses 37-38 — Anti-avoidance: company reconstructions
29 January 2026, ICAEW
Written submission to MPs from the ICAEW Tax Faculty, regarding the new anti-avoidance rules applicable to company reorganisations set out in clauses 37 and 38 of the Finance Bill.
Briefing for MPs — Clause 79 — Private hire vehicles or taxis
29 January 2026, ICAEW
Written submission to MPs from the ICAEW Tax Faculty, addressing the practical implications of the amendment to s53, VATA 1994, concerning the exclusion of taxis and private hire vehicles (PHVs) from the tour operators margin scheme (TOMS).
ICAEW REP 13/26: Finance Bill 2025-26, Clauses 163–173 — Promoter action notices
2 February 2026, ICAEW
Written submission to MPs from the ICAEW Tax Faculty, regarding the proposed introduction of Promoter Action Notices (PANs).
Finance Bill changes for individuals and businesses
3 February 2026, ICAEW
Podcast episode from ICAEW’s Tax Faculty looking at the implications of Finance Bill 2025-26 for individuals and businesses, from the reform of inheritance tax to changes to capital allowances.
Commentary from firms and other external advisers
Tax experts have produced analysis of various aspects of the Bill. A selection of commentary resources is set out below.
Research briefing: Budget 2025 and Finance (No. 2) Bill 2024-26
A guide produced by the House of Commons Library, highlighting key publications and information sources relating to the Budget 2025 and Finance (No. 2) Bill 2024-26.
Grant Thornton Insights
Articles and guides from Grant Thornton UK, including:
- Legislation Day (L-Day) 2025 (29 July 2025)
- Business and Agricultural Property Relief – draft law and updates announced (28 July 2025)
- New UK carried interest tax regime - summary of draft legislation published (28 July 2025)
KPMG Tax Matters Digest
A bi-weekly newsletter covering UK tax developments with KPMG's analysis. Key commentary on the Finance Bill 2025-26 includes:
- L-Day: Inheritance Tax Business and Agricultural Property Reliefs (24 July 2025)
- L-Day: UK carried interest draft legislation - initial observations (24 July 2025)
- L-Day: tackling non-compliance in the umbrella company market (24 July 2025)
- L-Day: getting CSOP and EMI options PISCES ready (24 July 2025)
- L-Day: Changes to Employee Car Ownership Schemes (ECOS) (24 July 2025)
- Carried interest reforms and the pension savings annual allowance (7 August 2025)
- IHT on Business and Agricultural Assets: Liabilities from April 2026 (13 November 2025)
- Finance Bill: More details emerge of the new 40% first year allowance (11 December 2025)
- Finance Bill: Details of advance tax certainty service published (11 December 2025)
- Finance Bill: Reform of international tax rules (11 December 2025)
- Finance Bill: Three year stamp duty holiday introduced for listings (11 December 2025)
- Finance Bill: Carbon Border Adjustment Mechanism (CBAM) (11 December 2025)
- Finance Bill: Umbrellas unfurled! (11 December 2025)
- Finance Bill: Other measures of note (11 December 2025)
- Advance Tax Certainty Service: HMRC release draft guidance (8 January 2026)
- Finance Bill: Update on progress (5 February 2026)
BDO Insights
News and opinion from BDO, including:
- Carried interest tax reform - how it will work from 6 April 2026 (25 July 2025)
- IHT business relief: Why trusts are important (8 January 2026)
RSM Tax Voice
Articles from RSM commenting on UK tax issues and news, including:
- UK carried interest tax reform: what you need to know (11 August 2025)
- Inheritance tax reform: key insights from the draft legislation (20 August 2025)
- Inheritance tax changes – key facts to know before the April 2026 deadline (24 November 2025)
Articles and books in the ICAEW Library collection
To find out how you can borrow books from the Library please see our guide to borrowing books.
You can obtain copies of articles or extracts of books and reports through our document supply service.
Archive
The Library holds an extensive collection of Finance Acts (from the 19th century onwards), Finance Bills (from 1951 onwards), debates on the Finance Bill as recorded in Hansard, and Standing Committee Debates on the Finance Bills. Alongside this you can also find many publications from the ICAEW and other bodies on the Finance Bills and Acts.
For full details of our holdings in this area, see our guide to Finance Acts and Bills in the Library collection.
We also maintain an online archive of links and resources for Finance Acts 1980–1995 and for Finance Acts 1996–.
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