HMRC is introducing a new framework designed to strengthen its powers against tax advisers who deliberately facilitate non-compliance. These changes mark a significant shift in how adviser conduct will be monitored and enforced, particularly in areas such as research and development tax relief, where scrutiny has intensified in recent years.

The key proposals include:

• Replacing the current “dishonest conduct” test with a broader “deliberate conduct” standard. This means advisers could now face penalties not only for dishonest actions but also for deliberate omissions or failures to act.
• Granting HMRC the ability to access adviser files and documentation without the need for prior tribunal approval.
• Introducing severe penalties of up to 100 per cent of lost tax revenue and the public naming of advisers involved in serious breaches.
• Implementing a mandatory registration process for all tax advisers from April 2026 to ensure only qualified and accountable professionals interact with HMRC on behalf of clients.

The objective is clear. HMRC aims to raise professional standards, increase accountability, and eliminate poor practices that undermine the integrity of the United Kingdom tax system.

At RD Tax, we view these reforms as a positive and necessary development. The research and development tax relief industry has, unfortunately, seen a rise in rogue operators in recent years. Some have exaggerated claims, misrepresented qualifying activities or misled clients about their eligibility. This behaviour damages client trust and undermines the credibility of legitimate R&D specialists who take compliance seriously.

We fully support HMRC’s efforts to remove such advisers from the market. Stronger regulation will help restore confidence in the R&D tax relief scheme and ensure it continues to reward genuine innovation.

Our approach at RD Tax has always been grounded in transparency, accuracy and compliance. Every claim we prepare is supported by:

• Detailed technical documentation and evidence of qualifying activities
• Independent internal review before submission
• Full audit trails and client approval
• Alignment with the DSIT Guidelines, HMRC’s CIRD Manual, and all relevant legislation

This structured approach gives our clients complete confidence that their claims are legitimate, defensible, and fully compliant with the applicable standards.

The new powers may appear daunting for some advisers, but for those who operate responsibly, they represent a welcome opportunity to raise standards across the industry. By focusing on robust evidence, ethical practice, and adherence to legislation, firms can help to rebuild the credibility of the R&D tax relief regime.

At RD Tax, we believe that genuine specialists have nothing to fear from greater scrutiny. These reforms will help to eliminate poor practice and ensure that innovation is rewarded fairly, transparently and in accordance with the law.