We recognise your commission on the right event, keep gross rent out of turnover and account for VAT on your fees.
Money you earn and money you hold for clients come through the same business. Only your commission belongs in turnover.
| Money in | Whose it is | In your turnover? |
|---|---|---|
| Commission on a completed sale | Yours | Yes, when the work for the seller is complete |
| Rent collected for a landlord | The landlord’s | No |
| Management fee | Yours | Yes, spread over the management period |
| Tenant-find fee | Yours | Yes, when the tenancy is secured |
| Tenancy deposit before it is protected | The tenant’s | No |
| Holding deposit | The prospective tenant’s | No |
| Renewal commission | Yours | Depends on your terms of business |
EAA 1979 s.13 holds clients’ money on trust for the person entitled to it. In Scotland s.13(2) holds it as agent.
Money held on trust for someone else is not a resource you control, so it is not your asset.
Paragraphs 23.36 to 23.37 make you an agent and confine your revenue to your commission.
For periods beginning on or after 1 January 2026, FRS 102 Section 23 is rewritten on IFRS 15 principles: identify the contract and its performance obligations, set and allocate the price, and recognise revenue as each obligation is met.
The new standard needs an answer on whether a renewal is a separate obligation or a right granted in the original contract. The answer comes from your terms of business.

Commission is standard-rated. Schedule 9 Group 1 exempts the grant of an interest in land, and an agent grants none. HMRC treats the engagement as a supply of services, normally to the seller.
Mortgage introductions can be exempt. Insurance introductions can be exempt under Group 2 when you give the written disclosure document legal notes (3) to (5) require, at or before the time the insurance is arranged.
Your fee is standard-rated for every landlord. A residential landlord generally cannot recover that VAT; an opted commercial landlord normally can.
Desks, computers and signage are main-pool plant, covered by the £1,000,000 Annual Investment Allowance. Lighting, wiring, heating and air conditioning are integral features in the 6% special rate pool. The main pool writing down allowance fell from 18% to 14% in April 2026.
Just your commission, and this is the single most common error in agency accounts. FRS 102 23.36 requires you to determine whether you promise to provide the service yourself, making you a principal, or to arrange for another party to provide it, making you an agent. 23.37 makes the test control: whether you control the specified good or service before it transfers to the customer. A lettings agency collecting rent controls nothing — the rent is the landlord's income passing through your client account. It is not your revenue and it should never appear in your turnover. The same reasoning applies to contractor repairs, referencing and inventories arranged on the landlord's behalf: only your margin is revenue.
It depends on your terms of business. FRS 102 does not contain a sector rule, and neither the FRC nor HMRC has published anything fixing a single date for estate agency commission. What the standard gives is a framework: 23.78 to 23.80 ask whether control transfers over time or at a point in time, decided at contract inception, and 23.85 onwards lists the indicators — including whether the entity has a present right to payment. What decides it in practice is your contract, which the law requires to be explicit anyway: EAA 1979 s.18 requires you to give the client, before they are committed, particulars of the circumstances in which they become liable to pay. Sole agency with commission due on completion recognises on completion. Commission earned on exchange recognises on exchange.
Section 23 was completely rewritten, and Section 20 changed too. The Periodic Review 2024 replaced the old revenue section with Section 23 Revenue from Contracts with Customers, based on IFRS 15 principles, effective for periods beginning on or after 1 January 2026 with early application permitted. Transition is either fully retrospective or modified retrospective. The five-step model now applies: identify the contract, identify the performance obligations, determine the transaction price, allocate it, and recognise revenue as each obligation is satisfied. Separately, Section 20 brings operating leases on balance sheet for lessees — which affects every agency with a high-street office lease and changes what your balance sheet looks like to a lender.
Differently from each other, under the Section 23 rules for periods beginning on or after 1 January 2026. A management fee is a performance obligation satisfied over time — FRS 102 23.81 covers the case where the customer simultaneously receives and consumes the benefit as you perform — so it is recognised across the management period. A tenant-find or let-only fee is a point-in-time obligation satisfied when the tenancy is secured. Renewal commissions are the hard case: whether the renewal is a separate performance obligation or a material right granted in the original contract. Section 23 has explicit requirements on non-refundable upfront fees and customer options at 23.29 to 23.35, and that is where the answer lives.
Only if it meets all eight of HMRC's disbursement conditions. HMRC's eight conditions, set out in VTAXPER39000, must all be met — including condition two, that the client and not the agent used the goods or services. Revenue and Customs Brief 6 of 2020, following the Brabners case, sharpened the test: a fee is not a disbursement where you use the output in making your own supply of professional services, because it is then a cost component of that supply. Portal advertising fails these conditions, because Rightmove supplies the service to you. Tenant referencing is directly analogous to Brabners, because you use the report to form your own recommendation. An EPC can be a disbursement, but only if the assessor contracts with the seller and you pay as authorised agent. Buy it in your own name and it is a recharge.
Worse than it was, and worth re-running. Dividend rates rose on 6 April 2026: the ordinary rate to 10.75% from 8.75%, the upper rate to 35.75% from 33.75%, with the additional rate unchanged at 39.35%. The dividend allowance is £500. Employer National Insurance is 15% above a £5,000 secondary threshold, and the Employment Allowance is £10,500 with the old £100,000 prior-year-liability cap removed — though a company whose sole director is its only employee still cannot claim it. Corporation tax is unchanged at 19% up to £50,000 and 25% above £250,000, with marginal relief between and the limits divided by the number of associated companies plus one. For a multi-branch group held through several companies, that division is the number to check first.
Buzz Financial Services is a trading style of Equity & General Financial Services Limited, authorised and regulated by the Financial Conduct Authority (FCA 474163).
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Read moreWe check how your commission is recognised and whether rent is sitting in turnover.