Who supervises UK accountancy firms for AML?
Last updated: August 13, 2026
UK accountancy firms can currently be supervised for AML by HMRC, a recognised professional body such as ICAEW or ACCA, or, in more limited circumstances, the FCA.
Which supervisor applies depends on the firm’s regulatory circumstances, not simply an individual accountant’s professional membership.
Although the FCA is due to take over AML supervision for the entire accountancy sector, the existing regime remains in place for now.
Key takeaways
- There is currently no single AML supervisor for the UK accountancy sector.
- Belonging to a professional body does not by itself establish who oversees the practice.
- HMRC generally covers firms that are not already supervised for AML by another body.
- Changes to ownership or professional affiliation can alter who supervises the firm.
- OPBAS assesses the performance of professional body supervisors rather than individual firms.
- The future FCA model will replace the present fragmented structure once implemented.
Who currently supervises UK accountancy firms for AML?
UK accountancy firms are supervised under the Money Laundering Regulations (MLRs) by HMRC, the FCA, or one of the following professional body supervisors (PBSs).
- Association of Accounting Technicians (AAT)
- Association of Chartered Certified Accountants (ACCA)
- Association of International Accountants (AIA)
- Association of Taxation Technicians (ATT)
- Chartered Accountants Ireland
- Chartered Institute of Management Accountants (CIMA)
- Chartered Institute of Taxation (CIOT)
- Insolvency Practitioners Association (IPA)
- Institute of Accountants and Bookkeepers (IAB)
- Institute of Certified Bookkeepers (ICB)
- Institute of Chartered Accountants in England and Wales (ICAEW)
- Institute of Chartered Accountants of Scotland (ICAS)
- Institute of Financial Accountants (IFA)
These bodies sit within the wider Schedule 1 PBS framework, which comprises 22 supervisors across the accountancy and legal sectors.
The FCA currently has a limited supervisory role, distinct from the wider responsibility it will assume once the new regime begins. Until that transition takes effect, existing arrangements continue.
When HMRC supervises an accountancy firm
HMRC supervises accountancy firms that are not already covered for AML by a professional body or the FCA. When HMRC is your supervisor, the firm is directly accountable to it for compliance with the MLRs.
HMRC can test the practice’s AML controls through targeted supervisory checks, with deficiencies capable of leading to remedial action or enforcement.
HMRC-supervised firms must also maintain their registration and meet the annual declaration and fee requirements.
Responsibility for those obligations should be clearly assigned so the firm does not lose its supervisory registration through an administrative failure.
In addition, firms should reassess their AML supervision after changes to ownership, professional affiliation, or the services they provide, because those factors can alter whether HMRC remains the appropriate supervisor.
When professional body AML supervision applies
Whether a PBS supervises the practice depends on the conditions set by that organisation. ACCA, for example, generally supervises a firm when members holding practising certificates have combined majority control.
Other PBSs apply their own criteria; ICAEW likewise requires the practice itself to fall within its AML supervisory scope.
How to confirm who supervises your firm for AML
A firm should be able to verify its AML supervisor through evidence that relates to the business itself.
When a professional body’s public register records AML-supervised status, that can provide confirmation; if the register does not provide a clear answer, the firm should obtain it directly from the respective body.
Crucially, a membership or practising certificate is not enough unless it specifically establishes AML supervision.
Practical takeaway: Firms also need to assess the regulated work being carried out. This becomes particularly relevant when accountancy services sit alongside TCSP activity, as the firm’s registration needs to reflect the services for which supervision is required.
What if an accountancy firm has no AML supervisor?
Regulated accountancy work cannot be carried on without AML supervision. If neither a PBS nor the FCA covers the relevant activity, the firm will normally need to register with HMRC.
Trading while unregistered can breach the MLRs and lead to a financial penalty or prosecution. By extension, any existing gap should therefore be corrected by identifying the affected activities and securing the required registration.
Additional restrictions apply when the practice also provides TCSP services. Those activities cannot begin under HMRC supervision until the application has been approved, including the required fit-and-proper checks.
What role does OPBAS play in accountancy AML supervision?
OPBAS sits within the FCA and scrutinises how PBSs carry out their AML responsibilities across the accountancy and legal services. This includes examining the quality of their supervisory work and identifying weaknesses in how firms are monitored.
Although OPBAS has no direct supervisory relationship with individual accountancy firms, its findings can influence how bodies such as the ICAEW and ACCA approach inspections, risk assessment, and enforcement.
Where the FCA transition sits
Firms under PBS supervision, together with accountancy and TCSP businesses supervised by HMRC, will move under the FCA once the new regime takes effect.
Professional bodies will continue their wider regulatory and membership functions, but they will no longer supervise firms under the MLRs.
The new AML era will also create a single FCA registration route for professional services firms.
The public register will show the businesses the FCA supervises, while its wider role will include risk-based monitoring and enforcement of the MLRs. This should make supervisory status considerably easier to verify than under the current system of separate authorities.
However, the planned FCA transition does not change the AML supervisor an accountancy firm deals with today.
The transition still requires legislative and operational work, and the government intends to use existing supervisory data and approvals where possible to reduce duplication during the transfer.
OPBAS will also remain in place while PBS supervision continues, before ceasing once the FCA has fully assumed responsibility.
In summary
Until the FCA takes over, accountancy firms need to know which authority currently supervises them under the MLRs and ensure there is no gap in coverage.
Without AML supervision, regulated work can become unlawful, with any resulting regulatory action capable of disrupting the firm’s ability to continue serving clients.
FAQs
A sole practitioner should check their professional body’s rules before assuming that the firm is covered. Some bodies supervise firms only when specific practice-level conditions are met. Personal membership or a practising certificate can be relevant indicators, but the practice should confirm that it is actually supervised.
Changes in ownership or professional standing should trigger a reassessment of the firm’s AML supervision, as a different control structure or affiliation can place the practice under another supervisor.
The annual declaration and supervision fee remain continuing compliance obligations for HMRC-supervised accountancy firms, which must also keep their registration details current. Missing the required annual declaration or fee payment can put the firm’s registration at risk, so governance arrangements need to allocate responsibility for monitoring deadlines and maintaining access to the HMRC online service.
No, OPBAS is unlikely to be the right contact for a practice checking its own supervision, as the organisation monitors accountancy and legal supervisory bodies themselves. For a firm-level question, HMRC or the relevant professional body is the appropriate point of contact.
No, current supervision arrangements remain, so the FCA has not yet replaced HMRC or PBSs even though the move has been confirmed. Practices should continue using their existing AML supervisor and review the position when official implementation details are published.
References and Source Material
- Money Laundering Regulations 2017
- HMRC, Risks common to accountancy service providers
- HMRC, Money laundering regulations: who needs to register
- HMRC, Accountancy service provider registration
- HMRC, Register or update your money laundering supervision
- FCA, OPBAS
- HM Treasury, Reform of the AML/CTF supervision regime: consultation response
- HM Treasury, AML/CTF supervision report 2023-24
