Accountants for estate and letting agents — client money, AML and tax WhatsApp us hello@accountantsforestateagents.co.uk
Accountants for Estate Agents
Estate and letting agents · Client money · AML

Sales and lettings are two different rulebooks.

One statutory trust and an annual audit. One scheme membership and a set of approval conditions. Different definitions, different triggers, different penalties — and if you do both, both are running at once.

6 monthsTo audit the client account after the period end — reg 8(1)
£30,000Maximum penalty for holding client money outside a CMP scheme
£10,000The letting AML threshold, in pounds not euros, from 30 June 2026
~215Estate agency entries on HMRC’s 2025–26 non-compliance list
The organising idea

Which regime are you actually in?

Estate agency work sits under the Estate Agents Act 1979 and the Accounts Regulations 1981: a statutory trust, a client account, prescribed records and an annual audit. Lettings sits under the Client Money Protection Regulations 2019: scheme membership, transparency duties and the approval conditions that come with them. Almost nothing carries across.

Worth knowingThe distinction is not academic. It decides whether you need a CMP scheme, whether you need an audit, who is allowed to sign it, what your records must contain, how long you keep them, and what a Trading Standards officer can fine you. Getting the regime wrong means getting all of it wrong — and the two sets of rules are close enough in vocabulary that it happens quietly.

Client money accounting

Two regimes, two rulebooks, two audit triggers. Which one you are actually in decides everything else on this list.

The two regimes

The client account audit

Audited by a qualified auditor within six months of the period end — and “qualified auditor” means something specific.

The audit

AML supervision

HMRC, not the FCA. Registering late is the breach HMRC publishes more than any other, and trading unregistered is a criminal offence.

AML supervision
The rest of the year

Accounts, tenant fees and the day you sell

Revenue recognition changed on 1 January 2026 with the rewritten FRS 102 Section 23. The Tenant Fees Act was amended on 1 May 2026 and lost its main enforcement lever. And a company selling a lettings book is taxed on income, not on a capital gain.

Agency accounts and tax

Commission recognised on the right event, gross rent kept out of turnover, and a new FRS 102 Section 23 that changed on 1 January 2026.

Accounts and tax

Lettings and the Tenant Fees Act

What you may charge, the new offence of inviting a prohibited payment, and the enforcement lever that was repealed in May.

Tenant fees

Buying or selling an agency

Why a company selling a lettings book is taxed as income, and why the buyer usually gets no relief on what it paid.

Buying and selling
Who we act for

Sales, lettings, both, or not open yet

Sales agencies

Estate Agents Act client account, statutory trust, and an audit most agents do not know is due.

More on sales agencies →

Letting agents

CMP scheme membership, and seven categories of client money agents routinely miss.

More on letting agents →

Combined agencies

Both rulebooks at once, running on different definitions of the same words.

More on combined agencies →

Starting an agency

Redress, AML, CMP and the client account — in the order they actually have to happen.

More on starting an agency →
Who does what

We do the accounting. A registered auditor signs the report.

Accountants for Estate Agents

Client account bookkeeping and the monthly three-way reconciliation. The records reg 6(3) actually prescribes — payer, capacity held, the interest in land, tracked separately by property. The agency's annual accounts, corporation tax or partnership return, payroll, VAT and the management figures you run the business on. All the preparation that decides whether the report comes back clean.

Buzz Accounting Ltd is licensed by the AAT and a member of the ICPA. It is not a chartered accountancy firm and not a registered auditor.

Anstey Bond LLP

Colin Ellis, ICAEW and a Responsible Individual, audits the client account and signs the report. Regulation 8(1) of the Estate Agents (Accounts) Regulations 1981 requires a qualified auditor, and EAA 1979 s.14(6)–(7) defines that as someone eligible for appointment as a statutory auditor under the Companies Act 2006. Propertymark says the same thing for its own Accountant’s Report, citing Companies Act 2006 s.1239.

Anstey Bond LLP is a separate firm, registered for audit by the ICAEW. Companies House OC360626.

Common questions

The things agency owners actually ask

Do sales and lettings follow the same client money rules?

No, and this is the most useful thing on this website. They are two separate statutory regimes that happen to use similar words. Estate agency work — selling — is governed by the Estate Agents Act 1979 ss.13 to 15 and the Estate Agents (Accounts) Regulations 1981: money is held on a statutory trust, paid into an account with the word “client” in its title, and audited annually. Lettings is governed by the Client Money Protection Regulations 2019, which require scheme membership instead. A combined agency is in both at once, with two rulebooks and two different audit triggers running side by side. Most generic accountancy advice treats them as one thing, and that is where the trouble starts.

Does our client account have to be audited?

If you do estate agency work and receive clients' money, yes. Regulation 8(1) of the Estate Agents (Accounts) Regulations 1981 requires the accounts to be audited “by a qualified auditor within six months after the end of each accounting period.” Not reviewed, not certified by your accountant — audited by someone eligible for appointment as a statutory auditor under the Companies Act 2006, which is what EAA 1979 s.14(6) and (7) define the term to mean. Failing to comply, or failing to produce the latest report to an enforcement officer on demand, is a summary offence under s.14(8) carrying a fine up to level 4 on the standard scale. We prepare everything the auditor needs and refer the report itself out, because we are not a registered auditor and will not pretend otherwise.

Where does the separate client account requirement actually come from?

Not from the 2019 CMP Regulations, which is where almost everybody looks. For lettings it is a condition of scheme approval: SI 2018/751 reg 5(2)(f) requires members to hold client money in a client money account with a bank or building society authorised by the FCA, and schemes must enforce that to keep their approval. Related conditions in reg 5(2) require written client money handling procedures, publication of those procedures on your website, and professional indemnity cover appropriate to the amount of client money held. For sales the obligation is statutory and much older — EAA 1979 s.14(1) requires payment into a client account “without delay”. The grace period that once let agents join a scheme while still arranging an account ended on 1 April 2020.

Who supervises estate agents for money laundering?

HMRC, and that did not change in the 2025 supervision reform. The Treasury's consultation response of 21 October 2025 confirmed the FCA will become the Single Professional Services Supervisor for legal, accountancy and trust and company service providers. Estate and letting agency businesses were discussed as a possible addition and were not included, so they remain with HMRC. What matters far more day to day is the registration timing: HMRC requires you to register before carrying on any estate agency activity, trading unregistered is a criminal offence, and failure to apply at the required time is the dominant breach in HMRC's published non-compliance list — with roughly 215 estate agency entries in 2025 to 2026, the largest sectoral group on the list.

Is our commission VATable?

Yes, standard-rated, and the exemption people reach for does not apply. Schedule 9 Group 1 exempts the grant of an interest in or right over land — an agent grants no such interest, it supplies services, and HMRC treats the engagement as a single supply of services normally to the seller. Group 5, the finance exemption, does not rescue it either: item 5 covers intermediary services in relation to financial transactions, and a land sale is not one. There are two genuine exceptions. Mortgage introductions can be exempt, because a loan is a financial transaction. Insurance introductions can be exempt under Group 2 — but only if you give the customer the written disclosure document the legal notes require, at or before the time the insurance is arranged. No document, no exemption.

Has the rent-in-advance position changed?

Completely, from 1 May 2026. Section 9 of the Renters' Rights Act 2025 prohibits rent in advance before an assured tenancy is entered into, and it binds letting agents as well as landlords — you may not invite it, encourage it, accept an offer of it or accept it, whether it is paid to you or to somebody else. Section 8 then limits what can be taken afterwards to the initial rent. In practice the government's own guide puts it as: up to one month's rent after the agreement is signed, and nothing at all before. There is a linked change in the Tenant Fees Act, where a new s.5A creates a separate breach for inviting or accepting a prohibited pre-tenancy payment — closing the “but the tenant offered” argument.

Do you publish agency valuation multiples?

No, and we would treat any that you are shown with care. We checked: HMRC's Capital Gains Manual goodwill pages and the Shares and Assets Valuation Manual publish no multiple of turnover, profit, EBITDA or managed-property income for estate or letting agencies, and no industry multiples of any kind. Anything circulating from a broker or the trade press is a market opinion and should be attributed to whoever is offering it. What HMRC does say is more useful anyway — goodwill attributable to the proprietor's personal skills does not transfer unless it is tied in by contract, which means the restrictive covenants are part of what is actually being bought.

Ready when you are

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