Who must register

HMRC guidelines

Business sectors supervised by HMRC

  • Art Market Participants buying or selling works of art where the transaction value (or a series of linked transactions) is £10,000 or more
  • Letting agency businesses renting property or land valued at the equivalent of £10,000 or more a month
  • Estate agency businesses
  • High value dealers handling cash payments for goods totalling £10,000 or more on a single transaction or linked transactions
  • Money service businesses not supervised by the Financial Conduct Authority (FCA)
  • Trust or company service providers not supervised by the FCA or a professional body
  • Accountancy service providers not supervised by a professional body
  • Bill payment service providers not supervised by the FCA
  • Telecommunications, digital and IT payment service providers not supervised by the FCA

You need to register with HMRC if you carry out activities typically associated with these types of organisations by way of business and you are not already registered.

Estate Agents

Businesses required to register where they carry out estate agency activity include:

  • Residential, commercial, agricultural and online estate agencies
  • Property and land auctioneers;
  • Land agents
  • Relocation agents and businesses providing property-search or home-finding services on behalf of buyers
  • Property finders, property sourcers, deal packagers, private-acquisition specialists and property investment brokers
  • Sub-agents and self-employed agents operating independently and carrying out estate agency activity in their own right
  • Asset management businesses that also provide estate agency services
  • Social housing associations involved in property sales, including relevant shared-ownership sales;
  • Letting or property management businesses that also provide estate agency services
  • Property developers carrying out estate agency activity, including certain developers using a separate company or SPV to sell properties owned by the developer
  • Businesses that purchase or part-exchange property directly from an owner for onward sale, including quick-sale businesses
  • Property competition businesses instructed by a seller to list or market a property
  • Business brokers or transfer agents where their activities involve brokering the sale or acquisition of an underlying freehold or leasehold interest
  • Solicitors carrying out estate agency activity separately from their legal practice.

More information about estate agency businesses regulations available hereclick here external link

Art market participants

Who should register.

An art market participant (AMP) must register for supervision by HMRC if the AMP is:

  1. A firm or sole practitioner who by way of business trades, or acts as an intermediary
  2. In the sale, or purchase of certain works of art for
  3. A value or total purchase price of £10,000 or more,
  4. In a single transaction, or a series of linked transactions

One must also register with HMRC if one is the operator of a Freeport storing works of art in the Freeport and the value for a person (or a series of linked persons) is £10,000 or more

The words above in bold are where most of the mistakes, confusion and questions arise about who qualifies as an AMP. If you are unsure:

  • if you are an "intermediary" or
  • if you are transacting with qualifying "works of art" or
  • how to calculate the "total purchase price" or
  • about what constitutes a "linked transaction",

More information about art market regulations available hereclick here external link


This information is based on content from HM Revenue & Customs (HMRC) and is used under the terms of the Open Government Licence v3.0click here external link

The original content can be found on the GOV.UK websiteclick here external link.