HMRC AML Supervision Fees Guide: What UK Businesses Pay in 2026

HMRC AML supervision fees are the charges that HM Revenue & Customs levies on businesses registered for anti-money laundering supervision under the Money Laundering Regulations 2017. The annual premises fee is £400. The one-off application fee for new registrations is £300. And the penalties for failing to register dwarf both figures combined.

The single largest category of HMRC money laundering penalties is not a failure of compliance procedures. It is a failure to register. In the six months to September 2025, HMRC issued 369 penalties totalling £1,881,237 across its supervised sectors. Of those, 332 were for trading without AML registration. Estate agents alone accounted for 170 penalties worth over £835,000.

TL;DR: HMRC charges £400 per year per premises for AML supervision, with a one-off £300 application fee for new registrations. Small businesses earning under £5,000 can claim a reduction to £200 per year. The fees changed on 1 December 2025 for the first time since May 2019. Over 90% of HMRC AML penalties are for registration failures, not compliance failures.

HMRC's fee structure changed on 1 December 2025, the first revision since May 2019. This guide covers every fee that HMRC-supervised businesses pay, who must register, what changed, and how to avoid the registration failures that account for the vast majority of enforcement action.

Who must register with HMRC for AML supervision?

Businesses in nine designated sectors must register with HMRC for AML supervision under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). The registration requirement applies only to businesses not already supervised by the Financial Conduct Authority (FCA), the Gambling Commission, or a designated professional body such as the Law Society, ICAEW, or ACCA.

The nine HMRC-supervised sectors are:

1. Money service businesses (currency exchange, money transmission, cheque cashing not supervised by the FCA)
2. High value dealers (any business handling cash payments for goods totalling €10,000 or more in a single transaction or series of linked transactions)
3. Trust or company service providers (not supervised by the FCA or a professional body)
4. Accountancy service providers (bookkeepers, tax advisers, and accountants not supervised by a professional body such as ICAEW or ACCA)
5. Estate agency businesses (all estate agents carrying out estate agency work as defined under the Estate Agents Act 1979)
6. Bill payment service providers (not supervised by the FCA)
7. Telecommunications, digital, and IT payment service providers (not supervised by the FCA)
8. Art market participants (buying or selling works of art where the transaction value is €10,000 or more)
9. Letting agency businesses (renting property or land valued at the equivalent of €10,000 or more per month)

A business must not trade in any of these sectors without registering with HMRC. There is no grace period for new businesses: registration must be in place before the business begins operating in a supervised sector.

Certain organisations are exempt: UK registered charities providing relevant services free of charge or at nominal cost, and public authorities funded by the Exchequer or council tax rather than service recipients.

For property professionals, the registration requirement affects estate agents, letting agents, and any accountancy service provider handling property transactions who is not already supervised by a professional body. Conveyancing solicitors are supervised by the SRA, not HMRC. For a detailed guide to verifying identity in property transactions, see Veyco's step-by-step guide.

HMRC AML supervision fee schedule (from 1 December 2025)

The fee structure below reflects the changes that took effect on 1 December 2025. These were the first revisions since May 2019. HMRC justified the increases as necessary to align fees with inflation and fund effective AML supervision.

All fees are non-refundable once the registration or test has been processed. The premises fee is only refundable in limited circumstances: where the business is found to be out of scope of the regulations, is already supervised by another body, has provided incomplete information, has failed a fit and proper test, or has voluntarily withdrawn its application before processing is complete.

What changed on 1 December 2025

The December 2025 fee revision was the product of a formal HMRC consultation process. HMRC originally proposed higher increases across several fee categories but reduced the final amounts following industry feedback.

Premises fee: £300 to £400

The annual premises fee increased by £100, or 33%. HMRC's rationale was that the fee had not changed since May 2019 and was broadly in line with cumulative CPI inflation over that period, which would have placed the fee at approximately £387 to £390 if indexed annually. The rounded figure of £400 was adopted.

For 94% of HMRC-supervised businesses that operate from a single premises, this represents the entire annual supervision cost (excluding the one-off application fee for new registrations).

Application fee: reintroduced at £300

The one-off application fee was reintroduced after previously being removed. It was originally proposed at £400 but reduced to £300 following consultation feedback. The application fee is waived entirely for businesses eligible for the small business fee reduction.

Fit and proper test fee: £150 to £500

This fee applies only to money service businesses and trust or company service providers. HMRC originally proposed increasing it to £700 but reduced the final amount to £500 after feedback that the proposed increase was disproportionate. The fee is payable once per person per business.

Sanctions administration charge: £1,500 to £2,000

The charge that HMRC levies when it imposes a penalty for regulatory non-compliance increased by £500.

Approvals process fee: unchanged at £40

The approvals fee, payable per beneficial owner, officer, or manager (BOOM) of a supervised business, remained at £40. This fee applies to accountancy service providers, estate agencies, letting agencies, art market participants, and high value dealers.

Small business fee reduction

Businesses with an annual turnover of less than £5,000 can claim the small business fee reduction (SBF). The mechanics are:

1. Pay the full application fee (£300, if applicable) and annual premises fee (£400) at the time of registration or annual declaration
2. After HMRC accepts the application or declaration, contact HMRC at AMLS.Fees@hmrc.gov.uk with documentation confirming turnover is below £5,000
3. Receive a £500 refund, reducing the effective annual cost to £200 for a single-premises business (or zero for businesses eligible for the waived application fee in subsequent years)

HMRC's own analysis found that fewer than 50% of eligible businesses were claiming the small business reduction. Following the December 2025 consultation, HMRC committed to conducting further outreach to remind small businesses of their eligibility.

So if you are a sole-practitioner letting agent, part-time bookkeeper, or small estate agency business, check whether you qualify. The reduction does not apply to the fit and proper test fee or the approvals process fee.

How to calculate your total HMRC AML supervision costs

The total annual cost depends on your business sector, number of premises, and whether it is a first registration or renewal.

Example 1: Single-premises estate agent (first registration)

Example 2: Multi-branch accountancy firm (3 premises, 2 BOOMs, renewal)

Example 3: Money service business (first registration, 1 premises, 3 persons tested)

The annual declaration: how to stay registered

Registration with HMRC is not a one-time event. Every 12 months, on the anniversary of your initial registration, you must complete an annual declaration and pay the premises fee to remain registered.

HMRC sends a notification to your online account 30 days before the declaration deadline. The process requires you to:

1. Log in to your HMRC online account for AML supervision
2. Confirm or update your business details, including premises, beneficial owners, officers, and managers
3. Pay the annual premises fee (£400 per premises, or £200 for the small business reduction)

If you do not complete the annual declaration and pay the fee by the deadline, HMRC will cancel your registration. Cancellation means the business is no longer authorised to trade in its supervised sector. Continuing to trade after cancellation is an offence that attracts the same penalties as trading without ever having registered.

But the most common failure pattern is straightforward: a business registers, operates compliantly for several years, and then misses an annual declaration because the responsible person changed role or the notification was not actioned. The consequence is automatic cancellation followed by a penalty for unregistered trading when the business continues to operate.

Contact MLRCIT@hmrc.gov.uk if you have issues with your annual declaration submission or fee payment.

Penalties for non-compliance

HMRC's enforcement data makes clear that registration failures dominate the penalty picture. In the six months from April to September 2025, HMRC published its latest enforcement update showing:

• 369 penalties issued across all supervised sectors, totalling £1,881,237
• 332 penalties (90%) were for trading without registration
• 170 penalties to estate agency businesses, totalling £835,842
• 134 penalties to accountancy service providers, totalling £513,930

The pattern has been consistent across multiple reporting periods. The overwhelming majority of HMRC AML penalties are for administrative failures, principally failing to register or failing to maintain registration, rather than for substantive compliance breaches such as inadequate customer due diligence or missing suspicious activity reports.

This means the businesses most at risk of penalties are not the ones with weak compliance procedures. They are the ones that did not register at all, or let their registration lapse by missing an annual declaration. The financial exposure from a single penalty for unregistered trading typically exceeds the total supervision fees that the business would have paid over several years of compliant registration.

For estate agents and letting agents handling property transactions, the AML obligations extend beyond HMRC registration to include customer due diligence on every client. For a guide to how identity verification works in property transactions, see Veyco's step-by-step guide.

How to register for HMRC AML supervision

Step 1: Check whether you need HMRC supervision

If your business operates in one of the nine supervised sectors and is not already supervised by the FCA, the Gambling Commission, or a designated professional body, you must register with HMRC. Use the GOV.UK guidance on who needs to register to confirm your obligation.

Step 2: Gather your information

Before starting the application, you will need:

• Your business name, address, and Companies House number (if applicable)
• Details of all premises where supervised activity takes place
• Names and details of all beneficial owners, officers, and managers (BOOMs)
• Your business turnover (to determine small business reduction eligibility)

Step 3: Apply online

Register through the HMRC online service for money laundering supervision. The application requires payment of the one-off application fee (£300), the premises fee (£400 per premises), and the applicable approval or fit and proper test fee.

Step 4: Complete the fit and proper or approvals process

Depending on your sector, HMRC will conduct either a fit and proper test (money service businesses and trust/company service providers, £500 per person) or an approvals process (all other sectors, £40 per person) for each BOOM.

Step 5: Receive confirmation

Once HMRC has processed your application and fees, you will receive confirmation of your registration. Your business will appear on the HMRC Supervised Business Register, which clients and counterparties can check to verify your registration status.

HMRC AML supervision vs other supervisory bodies

Not every business that carries out AML-regulated activity registers with HMRC. The UK supervisory structure is divided between HMRC and sector-specific bodies:

An important regulatory change is on the horizon. The FCA's Annual Work Programme 2026/27 formally commits the FCA to becoming the single AML supervisor for the legal sector, which will bring approximately 60,000 additional firms, including conveyancing solicitors, under FCA oversight. This transition will not affect HMRC's supervision of estate agents, letting agents, or accountancy service providers. But it signals a broader tightening of AML supervisory standards across the UK property sector.

Common mistakes that lead to penalties

Trading before registration is confirmed

A business must be registered before it begins operating in a supervised sector. Submitting an application does not authorise trading: only a confirmed registration does. Businesses that start operating while their application is being processed are technically trading without registration and are liable for a penalty.

Missing the annual declaration deadline

HMRC sends a 30-day advance notification to your online account. If the notification is not actioned, registration is cancelled automatically. Many penalties in HMRC's published enforcement data relate to businesses that were previously registered but failed to renew.

Assuming a professional body membership covers you

An accountant who is a member of a professional body like ICAEW is supervised by that body for AML purposes and does not need to register with HMRC. But an accountant who is not a member of a qualifying professional body must register with HMRC directly. The distinction catches sole practitioners and small firms that operate without professional body membership.

Not registering every premises

The premises fee is charged per location where supervised activity takes place. A business with three offices must register and pay for all three. Registering only the head office while conducting supervised activity from branch locations is a compliance failure.

Ignoring the small business reduction

HMRC's own data shows that fewer than half of eligible businesses claim the small business fee reduction. For businesses with turnover under £5,000, the reduction brings the effective annual cost from £400 to £200. That is a significant saving for sole traders and part-time practitioners.

AML compliance beyond registration

HMRC registration is the administrative foundation, but the compliance obligation does not end with payment of fees. MLR 2017 requires all supervised businesses to:

• Carry out customer due diligence (CDD) on every client before or during the establishment of a business relationship
• Conduct enhanced due diligence (EDD) where higher risk factors are present, such as PEP status, complex ownership structures, or transactions involving high-risk countries
• Maintain a written firm-wide risk assessment
• Appoint a nominated officer responsible for reporting suspicious activity to the National Crime Agency (NCA)
• File Suspicious Activity Reports (SARs) with the NCA when there are grounds for suspicion
• Keep records of all due diligence measures for at least five years

For estate agents and letting agents, this means running identity checks, sanctions screening, and PEP checks on every client involved in a property transaction. Since May 2025, mandatory sanctions checks apply to all letting and estate agents, requiring screening of every client against UK sanctions lists.

The gap between paying HMRC's supervision fees and actually implementing compliant AML procedures is where most substantive risk lies. Registration protects a business from the most common category of penalty (unregistered trading), but it does not protect against enforcement action for inadequate due diligence, missing SARs, or absent risk assessments. For a guide to automated KYC and AML checks in property transactions, see Veyco's overview. And for estate agents specifically, see Veyco's guide to AML for estate agents.

A single platform for AML compliance

Registration with HMRC is the first step. The ongoing obligation is to run identity verification, AML screening, PEP checks, and sanctions screening on every client, and to maintain an auditable record of each check.

Veyco consolidates identity verification, AML checks, PEP screening, and sanctions into a single workflow. Biometric verification is powered by Onfido, and most standard checks are completed in under 10 minutes. For estate agents and letting agents subject to HMRC supervision, the platform provides the auditable compliance record that HMRC expects to see during supervisory visits, without requiring multiple systems or manual record-keeping.

Book a demo to see how Veyco's compliance platform supports HMRC-supervised businesses.

Frequently asked questions about HMRC AML supervision fees

How much does HMRC AML supervision cost?

The annual premises fee is £400 per premises for most businesses, payable each year as part of the annual declaration. New registrations also pay a one-off application fee of £300. Additional fees depend on the business sector: money service businesses and trust/company service providers pay £500 per person for the fit and proper test, while estate agents, accountants, and other sectors pay £40 per person for the approvals process. Businesses with annual turnover under £5,000 can claim a small business fee reduction, receiving a £500 refund after their application or declaration is accepted.

Who needs to register with HMRC for AML supervision?

Businesses in nine designated sectors must register with HMRC if they are not already supervised by the FCA, the Gambling Commission, or a designated professional body. The sectors are: money service businesses, high value dealers, trust or company service providers, accountancy service providers, estate agency businesses, bill payment service providers, telecommunications and IT payment providers, art market participants, and letting agency businesses. A business must be registered before it begins trading in a supervised sector.

What happens if I don't register for HMRC AML supervision?

Trading without AML registration is an offence under MLR 2017. HMRC issues penalties for unregistered trading, and enforcement data shows that over 90% of all HMRC AML penalties relate to registration failures. In the six months to September 2025, HMRC issued 369 penalties totalling £1,881,237, with estate agents receiving 170 penalties worth over £835,000. The cost of a single penalty for unregistered trading typically exceeds the total supervision fees a business would have paid over several years of compliant registration.

When did HMRC AML supervision fees change?

The most recent fee changes took effect on 1 December 2025, representing the first revision since May 2019. The annual premises fee increased from £300 to £400, the fit and proper test fee increased from £150 to £500 (applying only to money service businesses and trust/company service providers), and a one-off application fee of £300 was reintroduced for new registrations. The approvals process fee remained unchanged at £40 per person.

How do I claim the HMRC small business fee reduction?

If your business turnover is less than £5,000, you can claim a small business fee reduction. Pay the full fees at the time of registration or annual declaration, then contact HMRC at AMLS.Fees@hmrc.gov.uk with documentation confirming your turnover is below £5,000. After your application or declaration has been accepted, HMRC will issue a £500 refund. The application fee is also waived for businesses eligible for the small business reduction. HMRC's own analysis shows that fewer than 50% of eligible businesses claim this reduction.

What is the HMRC annual declaration for AML supervision?

The annual declaration is a mandatory annual process that every HMRC-supervised business must complete to maintain its registration. It falls on the anniversary of your initial registration date, and HMRC sends a notification to your online account 30 days in advance. You must confirm or update your business details and pay the annual premises fee. Failure to complete the declaration and pay the fee by the deadline results in automatic cancellation of your registration, after which continued trading constitutes an offence.

Conclusion

HMRC AML supervision fees are modest: £400 per year for a single-premises business, with a small business reduction available for those earning under £5,000. The fee changes that took effect in December 2025 brought the first revision in over six years and remain broadly in line with inflation.

The real financial risk is not the fees themselves. It is the penalty for failing to register or failing to maintain registration. Over 90% of HMRC's AML penalties are for registration failures, and the average penalty amount dwarfs the annual supervision fees that would have prevented it. For estate agents alone, HMRC issued over £835,000 in penalties in a single six-month period, for an annual fee of £400.

Registration is the foundation, not the finish line. MLR 2017 requires customer due diligence, sanctions screening, PEP checks, and suspicious activity reporting on an ongoing basis. Veyco consolidates these compliance steps into a single platform, providing the auditable record that HMRC expects during supervisory visits. Book a demo to see how it works for HMRC-supervised businesses.