Professional bodies criticise new rules, saying replacement of current dishonest conduct rules ‘catch technical differences and genuine errors rather than deliberate wrongdoing’ by tax advisers.

The new sanctionable conduct rule comes into effect on 1 April giving HMRC draconian powers to act if they ‘suspect’ tax advisers of ‘sanctionable conduct’. The legislation is set out in Finance Act 2026 Schedule 22 ‘conduct of tax advisers’, replacing the old rules from 2012.

With a couple of weeks until the rules come into force, HMRC has published guidance on its approach to tax adviser sanctionable conduct, with major changes to the current system.