HMRC checklist
1. The annual declaration
This checklist prepares the business’s HMRC annual declaration (HMRC ECSH44875). It is not the declaration and does not submit it.
- The annual refresh has two stages: submit the declaration, then pay the fee. If either is missed, the registration is cancelled automatically (HMRC ECSH44875).
- The fee is £400 for each of the premises shown on the application (HMRC AML supervision fees). If turnover is less than £5,000, the business can apply for the small business reduction (HMRC AML supervision fees).
- Sign in with the details used to register for AML supervision, check the registration information, update it where needed and submit the declaration (HMRC ECSH44875). Then pay the fee, quoting the payment reference HMRC gives (HMRC ECSH44875). Keep a record of the date of the declaration and the payment reference with the business’s AML records.
- Before declaring, check that every premises, branch, beneficial owner, officer and manager is on the registration; a change of nominated officer or compliance officer is notified within 14 days of the appointment, other material changes within 30 days (HMRC AMLG1500; reg 21(4)).
The business is on HMRC’s register of supervised businesses, as the agency profile records.
The business has not recorded in the interview when its next annual declaration is due.
2. Registration and approval
- A business must not trade as an estate agency or letting agency business until it has applied to register with HMRC (HMRC AMLG2200; HMRC AMLG2300); it can trade as soon as it applies (HMRC AMLG2200). Trading as an estate agency business after the registration is cancelled is a criminal offence (GOV.UK: money laundering supervision for estate agency businesses).
- Every branch must be on the registration, and HMRC must be told of a new branch, and of the officers and managers there, within 30 days of it opening (HMRC AMLG2200).
- A change of nominated officer or compliance officer is notified within 14 days of the appointment, other material changes to the registration within 30 days (HMRC AMLG1500; reg 21(4)).
- Each year the business submits its annual declaration and pays the annual fee for each of its premises; if either stage is missed, the registration is cancelled automatically (HMRC ECSH44875; HMRC AML supervision fees).
HMRC registration up to date: The business is registered with HMRC for money laundering supervision for each kind of work it does, with every premises listed, and its annual declaration and fee are up to date. Last reviewed or completed: 10 January 2026.
Approval of beneficial owners, officers and managers: To be introduced (see Actions).
3. The records to have ready
The Regulations require the business to keep these records, and to give its risk assessment and the information it was based on to HMRC on request (reg 18(6)).
8 records: 5 held, 2 to introduce, 1 not applicable, 0 not answered yet.
| # | Record | Status | Where it is |
|---|---|---|---|
| 1 | An up-to-date written record of the firm-wide risk assessment (reg 18(4)). | Held | Firm-wide risk assessment: drafted in this pack, held once signed |
| 2 | An up-to-date written record of the proliferation financing risk assessment (reg 18A(4)). | To introduce | Firm-wide risk assessment: drafted in this pack, held once signed |
| 3 | A written record of the policies, controls and procedures, of any changes to them, and of how they were communicated within the business (reg 19(1)). | Held | AML policy, controls and procedures: drafted in this pack, held once signed |
| 4 | A written record of the training measures and of the training given (reg 24(1)(b)). | Held | The business’s own records |
| 5 | The internal suspicion reports made to the nominated officer, and the reasons for each decision (HMRC AMLG11100). | Not applicable Not applicable: no reports | Internal suspicious activity report: drafted in this pack, held once signed |
| 6 | Copies of the documents and information obtained for customer due diligence, and records of each transaction, for five years from the end of the relationship (reg 40(2); reg 40(3)). | Held | The business’s own records |
| 7 | The registration with HMRC for each kind of work, with every premises listed, and the annual declaration and fee up to date (HMRC AMLG1500; HMRC ECSH44875). | Held | The business’s own records |
| 8 | HMRC’s approval of each beneficial owner, officer and manager, or the application naming them (reg 26(1),(2)(c); HMRC AMLG1600). | To introduce | The business’s own records |
Actions
- Firm-wide risk assessment: action: Review the firm-wide risk assessment now (HMRC AMLG1800), sign the reviewed version as the written record (reg 18(4)), and record the new review date.
- Proliferation financing risk assessment: to be introduced — action: Adopt the proliferation financing section of the firm-wide risk assessment as the business’s proliferation financing risk assessment and keep it up to date (reg 18A(4)).
- AML policies, controls and procedures: action: Review and update these policies, controls and procedures now (reg 19(1)(b)), have senior management approve the reviewed version (reg 19(2)), and record the new review date (HMRC AMLG1900).
- AML training for relevant employees: action: Train every relevant employee again and set an annual cycle for it (reg 24(1)(a); HMRC AMLG11030); keep a written record of the training (reg 24(1)(b)).
- Approval of beneficial owners, officers and managers: to be introduced — action: Make sure every beneficial owner, officer or manager of the business, or the sole practitioner, is approved by HMRC (reg 26(1),(2)(c)), naming each new one to HMRC when appointed and paying the approval fee for each person tested (HMRC AMLG1600; HMRC AML supervision fees).
Sources
- HMRC, Economic Crime Supervision Handbook ECSH44875 (annual refresh of supervision). Cited: HMRC ECSH44875.
- HMRC, Anti-money laundering supervision: fees. Cited: HMRC AML supervision fees.
- HMRC, AMLG1500 (registration). Cited: HMRC AMLG1500.
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692), revised text in force 30 June 2026. Cited: reg 21(4); reg 18(6); reg 18(4); reg 18A(4); reg 19(1); reg 24(1)(b); reg 40(2); reg 40(3); reg 26(1),(2)(c); reg 19(1)(b); reg 19(2); reg 24(1)(a).
- HMRC, AMLG2200: estate agent business guidance (updated 22 July 2026). Cited: HMRC AMLG2200.
- HMRC, AMLG2300: letting agent business guidance (updated 23 July 2026). Cited: HMRC AMLG2300.
- HMRC, Money laundering supervision for estate agency businesses (GOV.UK, last updated 26 January 2021). Cited: GOV.UK: money laundering supervision for estate agency businesses.
- HMRC, AMLG11100 (reporting suspicious activity). Cited: HMRC AMLG11100.
- HMRC, AMLG1600 (fit and proper test and approval checks). Cited: HMRC AMLG1600.
- HMRC, AMLG1800 (risk assessment). Cited: HMRC AMLG1800.
- HMRC, AMLG1900 (policies, controls and procedures). Cited: HMRC AMLG1900.
- HMRC, AMLG11030 (training). Cited: HMRC AMLG11030.