HMRC Pillar 2 Top-up Tax Software Authorisation List: July 2026 Update
HMRC updated its authorised software register for Pillar 2 Top-up Taxes on 3 July 2026, adding new providers across two separate submission categories. For accounting firms and CFOs advising large corporate groups with a UK presence, the practical question is immediate: does your current or planned software sit on the right list, and does it cover every filing obligation your group faces?
What Pillar 2 Top-up Tax Actually Requires
The UK's Domestic Top-up Tax and Multinational Top-up Tax together implement the OECD/G20 global minimum corporate tax rate of 15% for the largest corporate groups. These are not optional regimes, and non-submission carries direct exposure for affected entities.
The Three Filing Obligations
HMRC identifies three distinct submission types, each with its own software requirements:
- UK Tax Return: the primary return for Domestic and Multinational Top-up Tax liability.
- Overseas Return Notification: required where a group relies on an overseas filing to satisfy UK obligations.
- Information Returns: a separate data submission covering group-level information; this category has its own authorised software list.
Below Threshold Notifications are slightly different. They can be submitted either through authorised commercial software or directly via HMRC's own Pillar 2 Digital Service, giving groups without a full software solution a narrow fallback route for that specific filing type only.
What Changed on 3 July 2026
The July 2026 update added one new provider to the UK Tax Returns and Overseas Return Notifications list and one new provider to the Information Returns list. This follows a series of earlier additions documented in the page's change history, which shows the register has been expanding steadily since it was first established.
Pattern of Additions Over Time
The change log shows multiple update rounds, each adding between one and two providers per category. The cumulative effect is a growing roster of authorised tools, but the list remains live and subject to further additions. HMRC is explicit that neither list is exhaustive and that both will be updated as additional providers complete authorisation.
For firms currently evaluating software, this has a direct implication: a provider that is not yet on the list may be working through the authorisation process. Checking the live HMRC page before finalising any procurement decision is essential.
HMRC's Position on Software Selection
HMRC does not endorse or rank any product. The authorisation process confirms that a provider's software can technically interface with HMRC's systems for the relevant submission type. It says nothing about the software's broader functionality, pricing, support quality, or suitability for a given group's complexity.
Where HMRC's Responsibility Ends
This distinction matters operationally. If a filing fails, contains errors, or triggers a correction notice, HMRC directs the entity to its software provider rather than offering technical assistance itself. Similarly, any difficulties using the software, including cases where a return error notification is received by email, sit with the provider to resolve. Firms should factor this into their supplier due diligence, particularly around service-level commitments and error-correction workflows.
Implications for Accounting Firms and CFOs
The practical risk of getting this wrong is not abstract. A group that submits a UK Tax Return using software that is not on the authorised list may find the submission rejected or treated as non-compliant. Given the scale of groups caught by the Pillar 2 threshold, penalties for late or defective filing can be material.
Key Actions for Advisers Right Now
- Confirm that the software your client group uses, or is procuring, appears on the correct HMRC list for each filing type it needs to submit.
- Check whether the group needs coverage under both lists (returns and information returns) or only one.
- If the group relies on an overseas filing structure, verify that the software also covers Overseas Return Notifications.
- Review the live HMRC page before any software procurement is finalised, as the list is updated on a rolling basis.
- Establish a direct support escalation path with the chosen provider in advance, not after an error notice arrives.
For firms with clients that span multiple jurisdictions, it is also worth noting that Pillar 2 qualified status determinations are being made at the country level. The EU has been active in confirming qualified status for member states' implementing rules, and these determinations can affect how a group's overseas filing interacts with its UK obligations. Our earlier coverage of the EU Pillar 2 qualified status confirmed for Cyprus IIR sets out how that process works in practice.
Software Authorisation Is Not the Same as Tax Advice
One nuance worth flagging to clients: HMRC's authorisation process is a technical gateway check. It confirms the software can submit data in the correct format. It does not validate the underlying tax positions, confirm that the group has applied the top-up tax calculations correctly, or substitute for professional advice on whether particular entities fall within scope.
For accounting firms looking to position themselves on UK digital asset and corporate tax compliance more broadly, the regulatory environment is shifting on multiple fronts. The FCA finalising the UK crypto regulatory framework is one parallel development that affects how digital asset holdings are reported and treated in group accounts, which in turn feeds into the Pillar 2 effective tax rate calculations for affected groups.
Selecting the Right Software: What to Assess
Because HMRC takes no position on which product firms should use, the selection decision falls entirely to the filer or their adviser. The following framework reflects the filing obligations set out in HMRC's own guidance.
| Filing Type | Can Use HMRC Digital Service? | Requires Authorised Commercial Software? |
|---|---|---|
| UK Tax Return | No | Yes |
| Overseas Return Notification | No | Yes |
| Information Returns | No | Yes (separate list) |
| Below Threshold Notification | Yes | Yes (either route) |
When evaluating providers on the authorised list, consider: the scope of filing types covered by a single licence, the provider's track record of maintaining authorisation across update rounds, integration capability with existing ERP or crypto bookkeeping software stacks, and the contractual terms around error correction and indemnity.
For groups with digital asset holdings, the interaction between crypto bookkeeping software and Pillar 2 calculations deserves specific attention. Digital asset accounting software that feeds the general ledger must produce data in a form that the Pillar 2 calculation engine can consume accurately. A gap at that interface is an audit risk, not just an operational inconvenience.
Source: HMRC / GOV.UK
What is the HMRC Pillar 2 authorised software list?
It is a register of commercial software providers that have completed HMRC's technical authorisation process for submitting Pillar 2 Top-up Tax filings, including UK Tax Returns, Overseas Return Notifications, and Information Returns. HMRC updates the list on a rolling basis as additional providers are authorised.
Does a group have to use software from the list, or can it file directly?
For UK Tax Returns, Overseas Return Notifications, and Information Returns, authorised commercial software is required. The only exception is Below Threshold Notifications, which can alternatively be submitted through HMRC's own Pillar 2 Digital Service.
What happens if a group submits using software that is not on the authorised list?
HMRC's guidance implies the submission must use authorised software to be valid. Using unauthorised software could result in a rejected submission or a compliance failure, with potential penalties for late or defective filing.
Which groups are in scope for Pillar 2 Top-up Tax in the UK?
The regime targets the largest corporate groups, implementing the OECD/G20 global minimum corporate tax rate of 15%. The specific revenue thresholds and scoping rules are set out in the relevant UK legislation; advisers should verify whether a particular group meets the criteria.
If there is an error in a filed return, who handles it?
HMRC directs all technical issues, including error notices received by email after submission, to the commercial software provider. Firms should establish a clear escalation path with their chosen provider before any errors arise, not after.