HMRC’s estate-agency guidance explains how anti-money laundering responsibilities apply when businesses use self-employed agents. Property Industry Eye highlighted the issue on 3 November 2026 following the manual’s July publication and October update.
The official guidance makes the business model and contract important. Where a principal controls an agent’s relevant activities and procedures, the principal is responsible for that activity and the agent’s compliance. Relevant agent premises must be included in its registration, including home or contact addresses where appropriate.
An agent with substantial independence, operating its own controls, must register directly for supervision. An agent also working on its own behalf needs independent registration for that activity. Franchise arrangements likewise depend on how control is exercised. A label such as self-employed or franchise does not settle the question on its own.
Turn the guidance into clear questions
A business can begin by comparing its written agreement with the way work actually happens. Who sets the procedures? Who checks customer information? Who decides when a concern needs escalating? If the answers are unclear or differ between colleagues, that is a useful issue to resolve with the person responsible for compliance.
For an agent joining a network, ask for a written explanation of the arrangement before assuming the network handles everything. Request the current procedures, the right contact for questions and a clear account of the records the agent is expected to maintain. Keep those instructions accessible during day-to-day work.
Review changes as well as onboarding
A practical review can also ask how new locations, changes in working arrangements and additional business activities are reported internally. A one-off explanation at joining is less useful if nobody knows whom to contact when the model changes.
This is a reason to check responsibilities, rather than an allegation that a particular network has failed to comply. The PIE coverage includes industry opinion; the legal position should be checked against HMRC’s own guidance and the circumstances of the business.
The official manual should be read alongside the other guidance it references. Where there is uncertainty about an actual registration or supervision arrangement, obtain a suitable professional assessment rather than treating a short news summary as a complete compliance review.