Letting agents joined the AML register in 2020. Since December, the fees and the threshold both moved.

Anti-money laundering supervision is not a certificate you obtain. It is a state you are in, and it carries duties that run continuously: customer due diligence, risk assessment, record keeping, staff training, and a named officer.

Estate agency has lived with this for years, and lettings has since 10 January 2020. It came in by the size of the rent rather than by the kind of firm, which is a quieter mechanism — a single tenancy at the top of a rent roll can bring a whole business into scope without any decision that looks like taking an obligation on.

What moved since December

The fees, on 1 December 2025. HMRC raised the yearly premises fee from £300 to £400, which it says is broadly in line with inflation since May 2019, and brought back a one-off £300 fee for a new registration. The £40 it charges for approving each person — owners, officers and managers — did not change. The £500 fit and proper test belongs to money service businesses and trust and company service providers, not to letting agents.

The threshold, on 30 June 2026. The amending regulations replaced “10,000 euros” with “£10,000”. A euro is worth less than a pound, so the line moved up: a letting between the two amounts was in scope before 30 June and is not now. It still counts if the rent reaches £10,000 for only part of the term.

HMRC’s own guidance pages, last updated in 2023, still give the threshold in euros. Where they disagree with the regulations, the regulations win.

The fee is the small part

£400 a premises is a line in a budget. The duties behind it are a change in how a lettings business runs, and three of them touch the file rather than the finances.

Customer due diligence means identifying and verifying who you are dealing with, and for a letting agent that question has more than one answer — the landlord, the tenant, sometimes a company behind the landlord, sometimes somebody paying who is neither.

The risk assessment has to be written, specific to your business, and revisited. A generic document downloaded from a trade body and filed is exactly the artefact a supervisor is trained to recognise.

Record keeping is the one that decides an inspection. What you checked, when, on what evidence, and what you concluded — held for the required period and retrievable on request.

Where this overlaps with something you are already building

If you are preparing for the Renters' Rights Act, you are already building a record habit — arrears histories, condition evidence, dated communications, because every possession ground now needs a file.

AML wants the same discipline pointed at a different question. The identity checks, their evidence and their dates belong in the same place as everything else about that tenancy, retrievable by the same search, with the same timestamps nobody typed in later. Building two separate record systems for two obligations is how both end up half-kept.

Three practical points

1. Check your rent roll against £10,000 a month, in writing. The test is each letting, not your turnover, and a threshold you have not consciously assessed is one you may already have crossed. If your only qualifying lettings sat between €10,000 and £10,000, ask HMRC in writing where that leaves you rather than deciding for yourself.
2. Date every identity check. A verified identity with no date attached tells a supervisor nothing about whether it was verified before or after the money moved.
3. Keep the negatives. The check you ran that came back clean is evidence you ran it. Systems that only store positive findings lose the proof of the work.

What this does not tell you

We are not giving regulatory advice. HMRC describes a reduced fee for some small businesses, and refunds the registration fee to those that qualify; we have not set out who does, so check before you budget.

It also does not tell you what your risk assessment should conclude, which depends on your client base, your geography and your payment patterns — and which is the part no template can do for you. The general argument about why the record beats the policy is in the audit trail note, and the work with letting agencies is where we apply it. If you want to know whether a given process is worth automating at all, the triage tool usually says no.