Significant changes afoot for AML supervision of tax advisers

At present, the CIOT and ATT are AML supervisors of approximately 1,500 firms. This article will be of interest to all members involved with these firms, as well as those subject to supervision by other professional bodies.

In 2023, HMT consulted on potential future changes to the AML supervisory regime. They picked up on the concerns that the most recent peer assessment of the UK by the Financial Action Task Force (FATF) had identified inconsistencies and weaknesses in the UK’s supervisory system – in particular in the professional services sector, where there are 22 professional body AML supervisors plus supervision by HMRC.

The consultation set out four potential models of supervision for consideration:

• OPBAS+: strengthening the supervision of the supervisors by the Office for Professional Body AML supervision;
• Professional Body Consolidation: supervision reduced from 22 professional bodies to a small number;
• Single Professional Services Supervisor: one public body supervising the legal and accountancy sectors; and
• Single AML Supervisor: one public body responsible for all supervision.

In the consultation responses by the CIOT and the ATT, both bodies were supportive of OPBAS+ as the most feasible and robust model. Responses included the following points amongst others:

• OPBAS+ would reduce the risk of a decrease in supervisory effectiveness in the short to medium term.
• The movement of vast numbers of firms from one supervisor to another posed a number of problems.
• There would be a potential loss of expertise on AML supervision within the accountancy sector if any model was adopted other than OPBAS+.
• OPBAS was still relatively new and improvements had been made, so it should be given longer.
• Models other than OPBAS+ were likely to result in increased costs which may not be proportionate for supervised firms.

On 21 October 2025, HM Treasury announced the outcome of the consultation. The model chosen is for there to be one Single Professional Services Supervisor (SPSS) and the SPSS chosen is the Financial Conduct Authority (FCA).

All supervision of accountancy service providers (which includes tax advisers) will move to the FCA but no date has been set for the changes. HM Treasury have issued a further consultation relating to duties, powers and accountability. The deadline for submission of responses was Christmas Eve but there is likely to be further engagement as legislation and transitional arrangements are developed. At present, it looks unlikely that changes to supervision arrangements will be introduced before early 2028.

The CIOT and ATT are engaging with the FCA, OPBAS and HMT and want to make the transition as smooth as possible for members. In the meantime, it is business as usual for those supervised by CIOT and ATT. We have put messaging out in weekly news about the changes and have set up dedicated areas on the CIOT and ATT websites.

We will issue updates in weekly news, AML newsletters and Tax Adviser articles as soon as more details are available. If members have any queries, they should email the Professional Standards team [email protected] or [email protected].

Jane Mellor 
Head of Professional Standards
[email protected]