When Letting Agents Must Register with HMRC

Letting agents get told to "do their AML" as if it's one task. It's two. Sanctions screening applies to every agent and every let. HMRC supervision under the Money Laundering Regulations 2017 applies only to high-value lettings. This page is the second of those. Screening, and what to do with a sanctions match, is covered in letting agent AML compliance.

This is general information, not legal advice. The rent threshold is the one in the Money Laundering Regulations for letting agency business, and it is denominated in euros.

The threshold

You are carrying on letting agency business if, in the course of business, you arrange for someone else to let land where:

• the tenancy is for a month or more, and
• the monthly rent is €10,000 or more.

One property over that line is enough. The rest of the portfolio being ordinary assured tenancies does not keep the agency out of scope. Work that never reaches the threshold is not letting agency business, and there is no HMRC registration for it.

A landlord who lets only property they own isn't a letting agent for this purpose. The same person, acting as agent for other landlords, is.

Register before the work

If you are in scope, you register with HMRC for anti-money-laundering supervision before you carry on that business. HMRC is the supervisor for letting agency businesses that are not already supervised by the FCA. Trading without registration, once you are in scope, is an offence under the regulations.

What registration then requires

Registration is the start of the file, not the end of it. An agency in scope needs:

• A written firm-wide risk assessment, kept up to date.
• Customer due diligence on the landlord and the tenant: who they are, and, where the risk calls for it, where the funds are coming from.
• A nominated officer, and training for the people who do the work.
• Records kept for the retention period in the regulations, which is five years after the business relationship ends.
• A report to the National Crime Agency where you know or suspect money laundering. That report is a suspicious activity report, and it is separate from a sanctions report to OFSI.

Sanctions still apply underneath

Staying under €10,000 a month doesn't remove sanctions screening. Since 14 May 2025 every letting agent screens landlords, tenants and guarantors against the UK Sanctions List, keeps a record, and reports a match they cannot rule out to OFSI. Vantage runs that screen and stores the result. It doesn't register an agency with HMRC or hold a customer-due-diligence file, but the sanctions check and audit trail are built in. Start a free trial.