We keep the client account records, prepare for the client account audit, and do the accounts, tax, VAT and payroll for estate and letting agencies across the UK.
Sales work sits under the Estate Agents Act 1979 and the Estate Agents (Accounts) Regulations 1981: a statutory trust, a client account, prescribed records and an annual audit. Lettings work sits under the Client Money Protection Regulations 2019: membership of an approved scheme, and the client account, written procedures and insurance that the scheme's approval conditions require.
The regime decides whether you need a CMP scheme, whether you need an audit, who may sign it, what your records must contain, how long you keep them, and what a Trading Standards officer can fine you. An agency that does both is in both.

Records to the reg 6(3) standard and a three-way reconciliation every month.
A qualified auditor's report within six months of your period end.
HMRC registration for every premises, and the annual declaration.
Commission recognised on the right event, and VAT on your fees.
What a tenant can be charged, and the changes from 1 May 2026.
How the sale is taxed and what a buyer checks first.

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.
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.
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.
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.
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.
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.
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. HMRC does say that goodwill attributable to the proprietor's personal skills does not transfer unless it is tied in by contract, so the restrictive covenants are part of what is being bought.
A free review of your client money position, your audit exposure and your AML registration.