HMRC Updates MLR Fee Payment Guidance: What Crypto Firms Must Know
HMRC updated its official guidance on paying Money Laundering Regulations fees on 19 October 2026. The revision touches bank account details, payment methods, and reference-number handling in ways that matter directly to any cryptoasset business registered or applying for registration under the MLR regime. Getting the payment wrong is not a minor administrative inconvenience: a late or misdirected fee can lead to registration cancellation, and that would force an operational halt.
What the October 2026 Guidance Update Covers
The GOV.UK page carries five substantive changes, each with a practical consequence for registered businesses.
Updated sort code and account number
The bank account details used by businesses that are registering or already registered online have been updated. If your finance team or your crypto bookkeeping software has saved the old sort code, payments made to the previous account may still clear, but there is no guarantee of timely allocation. Firms should update saved payee details immediately and confirm the current details directly on the GOV.UK guidance page before the next payment cycle.
Separate account details continue to apply for businesses whose account is held overseas, and a further distinct set applies to businesses that have not renewed online. The guidance makes clear that all payments must be made in pounds sterling; using a foreign currency will trigger bank conversion charges that HMRC will not absorb.
Reference number handling: a new risk flagged explicitly
The guidance now explicitly warns that using the wrong 14-character payment reference, the one beginning with "X" generated by the online service, can result in your payment being allocated to a different outstanding tax liability rather than your MLR supervision fee. HMRC will not automatically correct this. The firm must contact HMRC to request a reallocation, which takes time and introduces uncertainty about whether the original deadline is treated as met.
For any firm operating under time pressure at the end of a supervision period, this is a meaningful risk. The reference number must be noted at the point of registration or renewal and stored securely. If your practice uses crypto accounting software or a broader practice management system to track regulatory payment obligations, the reference number field deserves the same attention as a VAT or PAYE reference.
Cheque payments discontinued
The option to pay by cheque in the post no longer exists. This affects any firm that previously relied on postal payments, whether as a primary method or as a fallback when online systems were unavailable. From now on, all payments must go through one of the electronic channels described below.
Accepted Payment Methods and Their Timing Rules
The guidance consolidates the remaining payment options and is explicit about settlement timing, which matters because the MLR fee deadline is the date payment is received, not the date it is sent, with one exception.
Bank account approval (Pay by Bank Account)
Paying directly through your online or mobile banking account via the "pay by bank account" option is the fastest route. HMRC describes the payment as usually instant, though it can take up to two hours to appear. This is the cleanest option for firms operating close to a deadline.
Debit card and corporate credit card
Online card payments are accepted using a debit card or a corporate credit card. Personal credit cards are not accepted. There is a non-refundable surcharge for corporate credit card payments. Importantly, the payment date for card transactions is the date the payment is made, not the date it reaches HMRC's account, and this applies even on weekends and bank holidays. This is a meaningful distinction: if your deadline falls on a Monday and you pay by corporate card on the Saturday, the Saturday date counts.
CHAPS and Faster Payments
Payments made by CHAPS or Faster Payments are received the same day or the next working day. For high-value payments or those made close to a deadline, CHAPS offers certainty, though the sending bank will typically levy its own charge. Firms should verify their bank's processing cut-off times before relying on same-day settlement.
Bacs
Bacs transfers take three working days to reach HMRC. This is the method most likely to cause a missed deadline if a firm leaves payment until the final day of a supervision period. The guidance recommends checking the bank's own processing times and maximum transaction limits before initiating a Bacs payment.
Why the Deadline Rules Carry Real Consequences
The guidance is direct on the point of non-payment: if a firm does not pay its annual supervision fee on time, HMRC may cancel its registration. A cancelled MLR registration means the firm is no longer supervised, which in turn means it cannot legally carry on the activities that require supervision, including operating as a cryptoasset exchange provider or custodian wallet provider under the MLR 2017 regime.
Beyond cancellation, a late payment can trigger a financial penalty, interest, or both. The guidance specifies that if a deadline falls on a weekend or bank holiday, payment must reach HMRC by the end of the previous working day. Firms that set calendar reminders for the nominal deadline date without accounting for weekends will find themselves outside this window.
There is also the reference-number risk described above. A payment that lands in the right account but carries the wrong reference may be applied to a corporation tax, VAT, or PAYE liability instead. The firm's MLR fee account then shows as unpaid, even though the money has left the business. HMRC's process for reallocating such payments is manual and not instantaneous.
Accounting and Compliance Implications for Crypto Firms
For accounting firms and CFOs advising registered cryptoasset businesses
Firms advising MLR-registered cryptoasset businesses should treat this update as a prompt to audit payment workflows. The three actions with the highest risk-reduction value are: confirming saved bank details match the current GOV.UK guidance; storing the client's 14-character reference number in a retrievable location within the practice's digital asset accounting software or document management system; and building a payment calendar that accounts for weekends, bank holidays, and Bacs processing times.
Firms that manage payments on behalf of clients should also note that the non-refundable corporate card surcharge may need to be disclosed as a disbursement on client invoices, depending on the engagement letter terms.
The removal of cheque payments closes a method that some smaller firms may have used as a backup. If any client's payment mandate relied on postal cheque, that arrangement must now be replaced with an electronic method before the next fee cycle.
Separately, the explicit guidance on wrong reference numbers is a reminder that MLR fee payments should be tracked with the same rigour as any other regulatory payment obligation. Integration with crypto accounting software that carries a compliance calendar feature can reduce the manual burden and the risk of reference-number errors.
For context on how regulators are raising the bar on AML compliance more broadly, see our coverage of how AI is reshaping crypto AML supervision across the FCA, VARA, and HKMA.
For the MLR-registered business itself
If your firm handles its own fee payments rather than delegating to an accountant, the practical steps are straightforward but time-sensitive. Locate your 14-character reference number now, before the next deadline approaches. Cross-check the sort code and account number you have saved against the current GOV.UK page. Remove any cheque-based payment instruction from your processes. And if you normally pay by Bacs, consider switching to Faster Payments or the Pay by Bank Account option to eliminate the three-day settlement risk.
The MLR regime's penalty framework operates independently of whether a missed payment was deliberate or accidental. HMRC does not distinguish between a firm that refused to pay and one that paid to the wrong account using an outdated reference. The administrative consequence, up to and including registration cancellation, is the same.
For a broader view of HMRC's approach to digital compliance obligations, our earlier piece on HMRC's penalty factsheet for digital platform operators provides useful context on how the authority is tightening enforcement across digital financial services.
Frequently Asked Questions
What happens if I pay my MLR supervision fee using the wrong reference number?
HMRC's updated guidance warns that the payment may be allocated to a different tax liability you owe. You will need to contact HMRC and request that the payment be moved to your MLR fee account. Until that reallocation is confirmed, your fee may be treated as unpaid, potentially triggering late-payment consequences.
Can I still pay my MLR fee by cheque?
No. The October 2026 update confirms that cheque payments in the post are no longer accepted. All payments must be made electronically, using the Pay by Bank Account option, a debit or corporate credit card, CHAPS, Faster Payments, or Bacs.
My deadline falls on a Sunday. When does my payment need to reach HMRC?
The guidance is explicit: if the deadline falls on a weekend or bank holiday, payment must reach HMRC by the end of the previous working day. For a Sunday deadline, that means Friday. If you are paying by Bacs, allow three working days and plan accordingly.
Do the bank account details differ depending on how I am registered?
Yes. HMRC provides separate account details for businesses registered or registering online with a UK account, businesses with a UK account that have not renewed online, businesses with an overseas account registered online, and businesses with an overseas account that have not renewed online. Using the wrong set of details may delay allocation of your payment.
Is there a surcharge for paying by corporate credit card?
Yes. The guidance notes a non-refundable fee applies when paying by corporate credit or debit card. Personal credit cards are not accepted. Check your engagement letter or internal policy on whether this surcharge should be absorbed or recharged before using this method.