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The latest paragraphs for you to consider including in your CQS CPMS Policy.

Text for CQS CPMS Policy

CQS Policy: Regulatory Risk – Tax Adviser Status (update)

Purchase this policy: Risk Management Policy

Change date
17/06/2026
Word count
927
Deployment measure
7/10
Rationale

HMRC registration brings your firm within a sanctionable conduct framework carrying penalties of up to £1,000,000, publication on GOV.UK, and the power to suspend your ability to complete transactions. This updated section gives your COLP the framework to manage that exposure, from registration maintenance and file access escalation through to PII coverage and SRA breach reporting.

### Registration The Firm identifies failure to register or maintain registration as an HMRC tax adviser as a high-level operational risk. The Firm maintains a register of all senior managers …

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