Compliance
Navigating HMRC’s Upcoming Employer and Adviser Obligations
Major compliance shifts are due around payrolling of benefits in kind and mandatory registration of tax advisers—Geared toward cleaner tax administration.
By NomadicTax Research Team • 5 min read • March 31, 2026
## Crucial Compliance Changes You Can’t Ignore
Two major compliance initiatives are rolling out:
- From **6 April 2026**, most employers in the UK must **mandatory payroll benefits-in-kind (BiK)** reporting, not voluntary as before. ([gov.uk](https://www.gov.uk/government/publications/agent-update-issue-140/issue-140-of-agent-update?utm_source=openai))
- From **May 2026**, tax advisers who interact with HMRC must be **registered**. Non-compliant promoters may be barred from using HMRC systems or handling client cases. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/6925eb772945773cf12dd09a/Loan_Charge_Review_2025_-_Government_Response_.pdf?utm_source=openai))
## Why These Matter for Employers & Agents
### Employers
- Payrolling BiK simplifies employee reporting but requires system changes: integrating BiK reporting into payroll software, managing valuation of different benefits, and clearly communicating with affected employees. Missed or incorrect reporting may lead to penalties. ([gov.uk](https://www.gov.uk/government/publications/agent-update-issue-140/issue-140-of-agent-update?utm_source=openai))
### Tax Advisers & Promoters
- The mandatory registration targets those promoting tax avoidance: individuals or entities involved in schemes could lose access to HMRC systems and face restrictions in client engagements. Understand your status. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/6925eb772945773cf12dd09a/Loan_Charge_Review_2025_-_Government_Response_.pdf?utm_source=openai))
## Practical Action Steps
1. **Audit your payroll software** now to ensure it can handle BiKs: assessing benefits like company cars, accommodation, and loans.
2. **Train payroll and HR teams** so they value BiKs correctly and identify reporting requirements.
3. **Check adviser status and credentials**: Ensure you’re on the HMRC register or in the process of registering. Clear any issues around promoter penalties. Attorneys and consultants need compliance credentials.
4. **Documentation and contracts**: Advisors should revise engagement letters to reflect registration status and compliance obligations.
5. **Use guidance and tools**: HMRC has issued agent updates and technical specifications ahead of the transition. Start reviewing them. ([gov.uk](https://www.gov.uk/government/publications/agent-update-issue-140/issue-140-of-agent-update?utm_source=openai))
## Scenario Example
- A medium-sized firm offers accommodation to staff and provides company vehicles. By April 2026, the payroll team must include these BiKs on payroll for tax and NICs deductions. Delays will trigger discrepancies and possible penalties.
- A tax adviser who previously assisted clients with tax avoidance schemes but hasn’t registered by May 2026 might lose ability to file returns through HMRC systems, damaging both reputation and business continuity. Ensuring clean records and registration is non-negotiable.
## Summary Points
- BiK reporting under payroll is no longer optional—get your systems ready.
- Tax advisers must register by May 2026 to stay fully operational.
- Failure in these compliance areas risks penalties, disallowed claims, or loss of access.
- Early engagement with HMRC guidance will ease the transition.
- Advice: schedule internal workshops now to assign responsibilities and evaluate readiness.