HMRC supervises estate and letting agents for money laundering. Registration comes before trading.
Estate agency businesses are the largest sectoral group on HMRC’s 2025 to 2026 non-compliance list, with roughly 215 entries. For most of them the breach is failing to apply for registration at the required time.
HMRC requires registration before carrying on any activity as an estate agency business. Trading unregistered, or after registration is cancelled, is a criminal offence.
HMRC’s list covers every business doing estate agency work, including:
Estate and letting agents have been supervised by HMRC since 10 January 2020. The 2025 supervision reform moves legal, accountancy and trust and company service providers to the FCA. Estate and letting agents stay with HMRC.
Worked for an agency with two branches and two people tested
A new branch needs adding to the registration. There is no refund for removing premises.
From 30 June 2026 a letting agency is in scope for a tenancy of a month or more with rent of £10,000 or more a month. The threshold used to be €10,000.
At 2026 exchange rates the sterling figure is lower than the euro figure it replaced, so some tenancies that were outside the rules are now inside them. The threshold applies to commercial lettings as well as residential.
HMRC’s guidance page for letting agency businesses still shows the euro figure and was last updated in April 2023. The legislation takes precedence. If your compliance file was built from that page, re-run the test.
These are the points HMRC’s published penalties come from.
Your HMRC registration exists and is live.
It covers every premises you trade from.
The annual declaration is made and the fee paid.
The owners, officers and managers on the register are the people running the business.
If you carry out estate agency work, almost certainly. MLR 2017 reg 8(2)(f) brought estate agents and letting agents into scope on 10 January 2020. Regulation 13 defines an estate agent by reference to s.1 of the Estate Agents Act 1979 and extends it to interests in land outside the UK. HMRC's list of who must register covers residential agencies, commercial agencies, online agencies, auctioneers, land agents, relocation agents, letting agents offering estate services, business brokers and transfer agents who broker sales of client businesses, and sub-agents providing estate agency services to a main agency. If you are a sub-agent assuming the main agency's registration covers you, it does not.
£10,000 or more a month, in pounds, from 30 June 2026. It was €10,000 from 10 January 2020 until then. The change was made by reg 8 of the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, SI 2026/621, substituting the figure in MLR 2017 reg 13(4)(b)(ii). Two conditions must both be met: a term of a month or more, and rent of £10,000 or more per month during at least part of the term. It applies to land generally — commercial as well as residential. HMRC's own guidance page for letting agency businesses still says €10,000 and was last updated in April 2023. The legislation governs, but if you have been working from that page, check your position.
From 1 December 2025: a one-off, non-refundable application fee of £300; a premises registration fee of £400 per premises; and an annual declaration fee of £400 per premises on renewal. The approval process fee is £40 per beneficial owner, officer or manager tested. There is a small business reduction where turnover is below £5,000 — you pay in full and receive a £500 refund once accepted. Adding premises costs the full fee in the first six months of the registration year and half in the second. There is no refund for removing premises when a branch closes.
Registering late, overwhelmingly. HMRC's published non-compliance list for 2025 to 2026 shows penalties across all sectors ranging from £1,050 to £104,000, most clustering between £1,250 and £7,000. Estate agency businesses account for roughly 215 entries — the largest sectoral group published. Typical estate agency penalties run £1,250 to £5,500, with the largest at £18,200. The dominant breach, affecting the large majority of listed entities, is failure to apply for registration at the required time under reg 56. Secondary breaches are failure to notify material changes, no risk assessment, customer due diligence failures, policies and controls, training, record keeping, and failure to notify who the nominated officer is.
No. The Treasury's consultation response of 21 October 2025 chose a Single Professional Services Supervisor model with the FCA as the supervisor, and paragraph 2.11 sets out exactly what moves: legal service providers, accountancy service providers and trust and company service providers — everything currently supervised by a professional body supervisor, plus the ASPs and TCSPs currently supervised by HMRC. Estate and letting agency businesses were floated in the consultation as a possible addition and were not adopted. They stay with HMRC. Timing for the change that is happening is indicative only: the response says implementation depends on enabling legislation, funding and parliamentary time, and gives no firm date.
A written risk assessment specific to your business. Documented policies, controls and procedures. Customer due diligence on both sides of a transaction — buyer and seller — at appropriate stages, which is the part agents most often get half right by checking the seller and not the buyer. Enhanced due diligence including politically exposed persons. A nominated officer, whose identity must be notified. Suspicious activity reports to the National Crime Agency. Record keeping, staff training, and registration of beneficial owners, officers and managers who must pass the approval test. SI 2026/621 also amended reg 27 with updated monthly rent thresholds for letting agents, and reg 19 on policies and controls.
We check your AML registration as part of the review.