Will FCA AML supervision increase fees and costs for accountancy firms?
Last updated: May 11, 2026
Accountancy firms should expect FCA AML supervision to make compliance more expensive, especially where current supervision costs are low, bundled into wider professional fees, or hard to identify separately.
The core reason is the proposed funding model: HM Treasury expects the FCA to recover day-to-day AML costs from the professional services firms it supervises.
The final fee model is still unsettled, but the planning assumption for many firms should be a higher overall AML cost.
Key takeaways
- Accountancy firms should plan for a future direct FCA AML supervision fee.
- The final cost is not yet known, but the policy direction is clear: FCA supervision will be funded on a cost-recovery basis by supervised firms.
- Professional bodies, including the ACCA and ICAEW, have warned that small firms may face higher costs, possible dual-fee pressure, and added administration.
- Accountancy firms should budget for a more visible AML fee line and some transition administration.
- The impact will not be uniform, since it will depend on the firm’s current supervisor, structure, and whether existing professional body charges are reduced or reallocated.
Why FCA supervision is likely to increase AML-related costs
The most important fee change is the move from a mixed supervisory system to one where the FCA is expected to recover its AML supervision costs directly from its in-scope population.
Regulation 102 of the Money Laundering Regulations already gives the FCA and HMRC power to charge fees for reasonably incurred supervisory costs. HM Treasury’s proposal applies that approach to the FCA’s expanded AML role.
This distinction matters most where AML supervision is currently a low, bundled or barely visible cost. A standalone FCA charge will make the cost easier to see and, for some firms, harder to absorb.
For the wider context behind the supervision reform, read our full FCA AML transition report for accountancy firms
What accountancy firms pay for AML supervision now
There is no single current price for AML supervision in the accountancy sector.
- Some PBSs publish specific AML or OPBAS-related charges.
- Others publish broader membership, practising certificate, licence, firm, or regulatory fees where AML supervision may be included or connected but not isolated as a standalone levy.
- HMRC uses a statutory charging model.
The basis of charging also differs: some fees attach to firms, individuals, offices, or BOOMs, while others sit inside wider practice or regulatory charges. Note that BOOM is the regulatory shorthand for a beneficial owner, officer, or manager.
A few examples make the comparison problem clear:
- ACCA and ICAEW identify OPBAS levies.
- IFA includes AML supervision in its firm fee structure and shows a separate OPBAS fee per BOOM.
- ICAS has an AML licence fee per BOOM.
- HMRC uses application, premises and approval-related charges.
Current and future AML fee position
| Area | Current position | What may change under FCA supervision |
|---|---|---|
| PBS-supervised firms | Charged separately by some bodies and bundled into wider fees by others. | Possible standalone FCA charge, with any offset depending on PBS fee changes. |
| HMRC-supervised firms | Statutory fee model. | Future treatment depends on the transition arrangements. |
| Professional body membership and practising costs | Wider professional and regulatory charges remain. | These costs may continue even when AML supervision moves to the FCA. Any reduction will depend on the professional body. |
| Small-firm relief or concessions | HMRC has small-business refund treatment in some cases. PBS arrangements vary. | Future relief will depend on the FCA fee consultation. This will be one of the most important fee-design issues for small firms. |
Dual-fee and admin burden risks
The FCA has not published the accountancy firm fee schedule for its future AML regime. The main variables are the tariff, calculation basis, payment date and any micro-firm relief.
However, AML is only one part of the fee relationship, since it will not replace every function currently performed by PBSs. This is where dual-fee pressure could arise: an FCA AML charge on top of continuing professional body costs.
ACCA has raised the prospect of dual supervision and dual fees. ICAEW has also noted the risk of additional burden, including continued Practice Assurance monitoring.
That is not the same as paying twice for identical work, but firms should be wary of assuming a pound-for-pound reduction elsewhere.
The less visible cost is administration, such as confirming details, providing information, adapting to FCA processes, and evidencing fit-and-proper or ownership information where required.
For a small firm, that time can be just as material. Compliance administration often lands on the principal, MLRO, or practice manager; the same people who are already balancing client work, staff issues, and deadlines.
Practical cost planning for accountancy firms
A sensible response is to prepare without overengineering.
Add an AML supervision line to the forward budget and use a range rather than a single forecast. PBS-supervised firms can test a scenario where today’s low or bundled cost becomes a standalone annual charge. HMRC-supervised firms can compare current statutory fees with a different future tariff.
Review current professional body invoices now, and separate AML or OPBAS-related charges from wider membership, licence, or practice fees to make future comparisons easier.
Practical takeaway: Better organised AML records will not reduce the fee, but they may reduce the time cost of supervision. One clean-up area is checking how often accountants should update CDD for existing clients, since unclear review cycles can add avoidable work during a supervisory review.
When might FCA AML fees start?
The cost-recovery principle is already clear, but the actual FCA fee model, rates and start date remain unsettled.
Implementation depends on legislation, funding and transition planning. For budgeting, Evidentia’s current working horizon is 2028/29, but that is not a legal deadline.
For the full sequence of dates, read our separate article on when the FCA will take over AML supervision for accountants.
In summary
The FCA transition is not just a change of supervisor for accountancy firms. It is also likely to become a future cost issue.
The intended funding basis is cost-recovery from supervised firms. The unknown is the final FCA fee design. Current fee arrangements across professional body supervisors and HMRC are too varied for a single neat comparison.
The practical next step is to identify current AML-related fees, test a few cost scenarios, and watch for the consultation details that will turn the planning assumption into actual numbers.
To keep track of FCA fee consultations, AML supervision changes, and practical updates for accountancy firms, join Evidentia’s free newsletter below.
FAQs
Yes, the liklihood that FCA AML supervision will increase costs for most in-scope firms. The impact will depend on their current supervisor, fee structure, and any future offsets.
No, the FCA tariff, concessions and payment timetable have not been published. The FCA fee consultation is the key document to monitor.
ACCA, ICAEW, IFA and ICAS all provide examples of separately identified AML or OPBAS-related charges, but their models are not like-for-like.
HMRC charges statutory AML fees, including application, premises and approval-related charges. The amount depends on the firm’s activity and circumstances.
Yes, FCA AML fees may sit alongside continuing professional body charges for non-AML functions.
No FCA small-firm concession has been announced. Minimum fees and fee bands should be watched closely when the FCA consults.
No official start date has been set. For now, 2028/29 is a reasonable budgeting guide.
References and Source Material
- HM Treasury, Anti-Money Laundering/Counter Terrorist-Financing (AML/CTF) Supervision Reform: Duties, Powers, and Accountability Consultation
- HMRC, Anti-money laundering (AML) supervision fees: responses and next steps
- ACCA, Economic crime at risk of growing under incoming anti-money laundering regime
- ICAEW, Handing AML supervision to FCA will increase costs for business
- ICAEW, Fees for regulated areas and affiliates
- Norton Rose Fulbright: Getting ahead of the new FCA powers over professional services firms
