HMRC has confirmed that new regulatory requirements affecting Stamp Duty Land Tax (SDLT) submissions will come into force from May 2026. The changes form part of the Government’s wider programme, announced in the Autumn 2025 Budget, to modernise and strengthen oversight of those interacting with HMRC on behalf of clients.
Under the forthcoming Finance Bill 2025–2026, individuals and organisations that deal with HMRC for clients will be required to register as tax advisers and meet new minimum standards. This will apply to a broad range of activities, including submitting tax returns, corresponding with HMRC, and providing information via telephone, email or online portals.
HMRC has confirmed that SDLT submissions fall within the scope of this new regime. Importantly, the act of filing an SDLT return will now be classified as “tax advice” for registration purposes, even where the professional involved does not provide wider tax planning or advisory services. As a result, professionals responsible for submitting SDLT returns as part of property transactions are likely to be caught by the new requirements.
The changes are expected to take effect from May 2026, alongside a transitional period of at least three months to allow firms time to adapt their processes and ensure compliance. HMRC previously indicated that practical guidance would be published in January 2026, but this has not yet been issued.
Some key aspects of the new framework remain unclear. In particular, it is not yet confirmed whether registration will be required at an individual level, a firm-wide level, or both. Industry bodies have also raised concerns about the breadth of the definitions used and how they will apply in practice, especially within the context of property transactions where SDLT submissions are often handled as part of a wider conveyancing service.
Once final guidance is published, clients may notice changes to the administrative processes surrounding SDLT submissions.
We are monitoring developments closely and will provide further updates once HMRC issues additional clarification. If you have any questions about how these changes may affect your property transaction, our team will be happy to advise.
