Will accountants need to register with the FCA for AML supervision?
Last updated: May 9, 2026
In-scope accountancy firms are likely to be subject to an FCA registration or onboarding process once the new AML supervision regime is implemented. There is nothing to apply for yet, because the FCA has not confirmed the exact transition details.
For the moment, the current AML rules still apply. Most firms remain under their professional body route, while in-scope firms outside that route may need HMRC registration.
The unresolved point is what that future route will involve. HM Treasury’s current intention is that existing supervised firms should not need full re-registration from scratch, but some form of data check, gatekeeping, or phased transfer remains possible.
Contents
Key takeaways
- FCA registration is likely to apply to in-scope accountancy firms once the new AML regime is implemented, but there is no process to complete yet.
- For existing supervised firms, the process is likely to involve transfer, onboarding, or data confirmation rather than a full fresh application from scratch.
- Professional body membership is not always the same as AML supervision, so firms should check their actual AML supervisory status.
- The most useful preparation is to ensure that firm details, services, responsible people, and BOOM information are accurate before any FCA process begins.
Current position vs expected FCA position
The table below separates the current AML position from the expected FCA model, so firms can see what is known, what is likely, and what still depends on the final transition process.
| Question | Current position | Expected FCA position | What is still unknown |
|---|---|---|---|
| Who supervises accountancy firms for AML? | A professional body route where applicable; otherwise, HMRC for in-scope firms outside that route | The FCA will supervise in-scope accountancy service providers | Final start date and transition mechanics |
| Are professional body-supervised firms included? | Yes, where the firm is covered by that body for AML | Expected to move into FCA AML supervision | What data firms must confirm |
| Are HMRC-supervised accountancy firms included? | Yes, where the firm is registered with HMRC for AML | Expected to move into FCA AML supervision | How transfer or onboarding will work |
| Will firms register with the FCA? | Not under the current system | FCA registration, onboarding, or confirmation is likely | Final portal, form, deadlines, and register format |
| Will there be a public register? | Current arrangements vary | HM Treasury has proposed an FCA register | What information will appear |
The registration question is only one part of the wider supervisory change. Our full FCA AML transition report for accountancy firms explains the broader reform, likely impact, and preparation points.
How AML registration works now for accountancy firms
Before any FCA application route opens, accountancy firms need to know where they sit under today’s AML regime.
In most cases, AML oversight sits with a professional body such as ICAEW, ACCA, AAT, or another recognised supervisor, depending on the firm’s status and activities.
Other accountancy service providers fall under HMRC, usually where they carry out regulated accountancy, tax, bookkeeping, or payroll-related services without professional-body AML cover.
The trap is assuming that professional membership automatically means AML cover. A firm should be able to show who oversees it for AML, which services are covered, and whether its details are current.
Until the FCA transition happens, the existing route remains the one that firms must keep accurate.
What FCA registration or onboarding could involve
Current route
Firm remains with its current AML supervisor: professional body or HMRC.
FCA process designed
Registration, onboarding, data checks and gatekeeping details are finalised.
Future position
In-scope firms move into the FCA AML supervision framework.
HM Treasury’s follow-on consultation suggests that FCA registration may be more than a basic form. The proposed model includes registration powers, gatekeeping checks, a possible public register, and the ability to refuse, suspend, or cancel a firm’s AML registration.
For a small accountancy practice, the focus is likely to be whether the regulator has a clear picture of the business and the people behind it. That could include legal and trading names, premises, contact details, current AML route, and services provided.
The services question is important because one practice may offer more than one regulated activity. Accounts preparation, bookkeeping, tax advice, payroll linked to tax or accountancy support, and trust or company service provider work may all be relevant.
The FCA may also need information about the people responsible for, or able to control, the business. That could include the nominated officer or MLRO, principals, partners, directors, senior managers, and BOOMs (beneficial owner, officer, or manager)
Gatekeeping is the more serious part. HM Treasury is considering fit-and-proper checks across the new professional services population. In simple terms, the regulator may need to assess whether the business and relevant individuals are suitable before accepting or continuing registration.
Will existing supervised firms need full re-registration?
HM Treasury’s stated intention is that accountancy firms already under a professional body or HMRC should not need full re-registration.
This stipulation does not settle the practical route, however. Existing firms may still need to confirm information, update details, respond to onboarding requests, or complete checks as part of the move to FCA supervision.
One credible planning assumption is that existing supervisors will pass information to the FCA, with firms then asked to validate or supplement it. Another possibility is phased onboarding, with different groups moved across at different points. However, the final registration model has not been confirmed.
Nonetheless, for owner-led practices, the main risk is assuming that “already supervised” means “nothing to do”. Even a light-touch transfer could be slowed down by inconsistent records, outdated responsible-person details, unclear service descriptions, or missing ownership information.
Related cost question: FCA registration and supervision may also affect AML compliance fees. Read our separate guide to FCA AML costs for accountancy firms to assess how these fees may impact your business.
TCSP and mixed-activity firms
Some accountancy firms also provide trust or company service provider services. This can include company formation, registered office or business address services, nominee director arrangements, trustee services, or arranging for others to act as directors or company secretaries.
Importantly, TCSP work is also within the proposed FCA-supervised population. HMRC guidance says it is not unusual for an accountancy service provider to provide ancillary TCSP services, and current AML supervision should reflect each activity type where both are provided.
Mixed activity can also affect fit-and-proper considerations under the current regime. A firm that thinks of itself mainly as an accountancy or tax practice should still check whether add-on company services bring it into TCSP territory.
What accountancy firms should check now
Small accountancy firms do not need a lengthy transition project, but they do need a clear view of their current AML position.
The starting point is the firm’s current AML route. A professional body-supervised firm should be able to evidence that its AML cover sits under the Money Laundering Regulations. An HMRC-registered firm should be able to show that its registration reflects the services it actually provides.
The service list is another important area to review. Accounts preparation, bookkeeping, tax advice, tax return support, payroll with accountancy or tax support, and advisory work may all be relevant depending on the facts.
TCSP activity also deserves a separate check. Company formation, registered office, business address, nominee, trustee, or director-arrangement services can affect the firm’s AML position.
Core firm information should also be kept tidy, especially details about the practice, its current AML route, and the people responsible for or able to control the business.
The objective is simple: when the official FCA process arrives, firms should be able to provide consistent answers quickly. For the timetable behind the change, see our article on when the FCA will take over AML supervision of accountants.
In summary
While the government has chosen the FCA as the future Single Professional Services Supervisor, the operational route for existing firms is still to be designed.
When the new AML regime is implemented, in-scope firms are likely to face some form of FCA registration, onboarding, or confirmation. This is expected to include firms supervised by professional bodies and those registered with HMRC for AML.
The sensible step for small practices is to get the basics right now. Firms should know their current supervisor, check that supervised activities match their services, identify any TCSP work, and keep responsible-person and ownership details current.
As the FCA registration and onboarding process develops, Evidentia covers the practical changes small accountancy firms need to understand. Join the free newsletter below to keep up with the main developments.
FAQs
Yes, if the accountancy firm is within scope for AML supervision, then they will likely need to be registered directly with the FCA.
No. Accountancy firms should wait for the official FCA process and continue to follow their current AML supervision route.
Yes, that is the current policy direction for firms supervised for AML by professional body supervisors.
Yes, HMRC-supervised accountancy service providers are also expected to be included in the FCA-supervised population.
HM Treasury’s stated intention is that already supervised firms should not need full re-registration, but they may still need to confirm or update information.
No, accountancy firms should check whether it is specifically supervised for AML under the Money Laundering Regulations.
Possible details include firm identity, services, current supervisor, responsible people, BOOMs, and information needed for a public register or gatekeeping checks.
TCSP services are also within the scope of the proposed FCA-supervised model and may affect AML registration, supervision, and fit-and-proper checks.
References and Source Material
- HM Treasury, Anti-Money Laundering/Counter Terrorist-Financing (AML/CTF) Supervision Reform: Duties, Powers, and Accountability Consultation
- HMRC, Who needs to register for money laundering supervision
- HMRC, Check if you need to register for money laundering supervision if you’re an accountancy service provider
- HMRC, Economic Crime Supervision Handbook
- ICAEW, AML supervision reform: Duties, powers, and accountability consultation
