HMRC guidance tightens AML compliance for self-employed agents

Self-employed estate agents and the networks they operate under face increased scrutiny of their anti-money laundering procedures following updated guidance from HMRC.

The updated AML guidance, published last month, clarifies how existing requirements apply to self-employed agents, home-based businesses, and franchise networks, particularly regarding registration, supervision, and accountability.

According to the guidance, estate agency networks bear responsibility for AML compliance where their self-employed agents operate under the network’s supervision and procedures. Networks must include relevant business premises used by their self-employed agents in their HMRC AML registration, potentially including home addresses where agents lack a separate office.

Agents operating independently, with responsibility for their own business activities and AML procedures, may need to register separately with HMRC, the guidance states.

Market share growth

The guidance comes as research from TwentyEA shows self-employed agents have increased their share of the UK property market from an estimated 2.2% in 2025 to 2.8% in 2026. The sector is reporting a higher likelihood of selling a property (65.2% versus 53.1% for traditional agents) and faster average completion times (142 days versus 152 days).

Marc von Grundherr, director of Benham and Reeves, said the updated guidance represents a significant development for the sector. “Estate agents are entrusted with facilitating some of the largest financial transactions people will ever make, and the same standards must apply regardless of whether an agent operates from a high street branch or their kitchen table,” he stated.

The trend towards self-employed agency models has drawn parallels with recent changes in commission structures for high-producing teams, reflecting broader shifts in how agents operate within the UK property market.

Compliance implications

Von Grundherr noted that whilst the self-employed model provides an alternative career path for those unable to commit to traditional full-time employment, this flexibility cannot compromise proper procedures, regulatory compliance, and financial accountability.

The guidance aims to establish consistent standards across the industry, regardless of business model or operating location. Networks supporting self-employed agents will need to ensure their compliance frameworks extend to all agents operating under their supervision.

The updated HMRC guidance follows broader regulatory developments affecting the property sector, with compliance requirements continuing to evolve across various aspects of property transactions and agent operations.

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