Updated HMRC guidance is placing greater anti-money laundering (AML) scrutiny on self-employed estate agency networks, clarifying that networks are responsible for compliance when agents follow their supervision and procedures.
Published in July and updated in October 2026, the guidance sets out obligations around registration, supervision and accountability. It also raises questions about how networks oversee agents operating under their brands.
Registration and supervision duties
Under the guidance, networks must include relevant business premises in their HMRC AML registration. This could include agents' home addresses if they work without a separate office.
However, agents who operate independently and manage their own AML procedures may need to register separately with HMRC. Businesses could also face penalties if they fail to meet their AML obligations.
For larger networks, the requirements could mean more administration and closer oversight of individual agents.
Self-employed agents increase market share
The clarification comes as self-employed agents gain ground in the UK property market. Research from TwentyEA shows their estimated market share rose from 2.2% in 2025 to 2.8% in 2026, an increase of 0.6 percentage points, or around 27% in relative terms.
The research also found that self-employed agents achieved a higher sales success rate than traditional agents. Their success rate stood at 65.2%, compared with 53.1% for traditional agencies. Average completion times were also shorter, at 142 days compared with 152 days.
However, the figures do not establish whether the agency model itself explains these differences.
Same standards must apply
Marc von Grundherr, director of Benham and Reeves, welcomed the guidance and called for greater scrutiny of self-employed agents. "It's high time that greater scrutiny was placed on the self-employed estate agency sector," he said.
"Whilst the model provides an alternative career path for those who may not be able to commit to traditional full-time employment, this flexibility cannot come at the expense of proper procedures, regulatory compliance and financial accountability."
He argued that self-employed agents should meet the same compliance standards as traditional high street agencies. "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."
Von Grundherr added: "The updated HMRC guidance is a welcome step towards ensuring a level playing field across the industry and, ultimately, protecting consumers."
