Will accountants need to register with the FCA for AML supervision?
Last updated: June 25, 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 confirmation, gatekeeping check, or phased transfer is still possible.
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 is expected, although the process is not live yet | Final portal, form, deadlines, and register format |
| Will there be a public register? | Current arrangements vary | The expected model includes an FCA public 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 when 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, firms still need to keep their current AML supervision position accurate and up to date.
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.
The future FCA process is expected to go beyond a basic form. The model includes registration and gatekeeping powers, including the ability to refuse, suspend, or cancel a firm’s AML registration, alongside a public register.
In a small accountancy practice, the regulator is likely to focus on whether it has a clear picture of the business and who sits behind it. That may include legal and trading names, premises, contact details, supervisor details, and services provided.
The services question is also 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. This could include the nominated officer or MLRO and the firm’s BOOMs (beneficial owner, officer, or manager). It could also include principals, partners, directors, and senior managers.
Gatekeeping is the more serious part, as fit-and-proper checks are expected to apply 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 validate records 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 in time. 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, or trustee services. It can also cover arranging for others to act as directors or company secretaries.
Importantly, TCSP work is also within the expected 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 if 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 require a lengthy transition project, but they should have clean and consistent AML records.
- Start by confirming who supervises the firm for AML purposes. A professional body-supervised firm should evidence that its AML cover sits under the Money Laundering Regulations. Similarly, an HMRC-registered firm should check that its registration reflects the services it actually provides.
- Next, review the firm’s service profile against the categories discussed above, focusing on whether the records reflect the work actually carried out.
- TCSP activity should be flagged separately because it may affect both the AML scope and any future FCA gatekeeping assessment.
- Core firm information should also be kept tidy, especially practice details and information about the people responsible for, or able to control, the business.
The objective is to protect against avoidable delays once the official FCA process begins. 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 registration process and transfer route for existing firms are still to be finalised.
The sensible step for small practices is to get the basics right now. Firms should know their current supervisor and check that their supervised activities match their services. They should also identify any TCSP work and keep the responsible person and ownership details current.
As the FCA registration and onboarding process develops, Evidentia will continue to update this page with core updates.
FAQs
Yes, if the accountancy firm is within scope for AML supervision, then FCA registration is expected under the future model.
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 expected 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
