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Estate Agency Launch Programme · Stage 3 of 10
Get Compliant to Trade
Put every mandatory registration in place so you can lawfully take your first instruction, then take proper advice on anything you’re unsure of.
How long
1–2 weeks
You’ll have
A lawful basis to trade, with every registration live
Steps
5 steps
Resources
2 resources
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01 Step 01
Step 01
Join a government-approved redress scheme
Redress membership is a legal condition of trading. Take one instruction without it and every listing is unlawful, with fines to match.
Do it yourself
- Choose one of the two government-approved schemes: The Property Ombudsman (TPO) or the Property Redress Scheme (PRS).
- Register the business, confirming whether you need cover for sales, lettings, or both.
- Adopt and follow the scheme’s Code of Practice.
- Display your membership on the office, website and letterheads.
Common mistake · Taking a single instruction before membership is live. From that first listing you are trading unlawfully.
Time~1–2 hours CostFrom roughly £150–£300+/yr depending on scheme and cover (indicative; confirm live figures on the scheme site) DifficultyEasyResource for this step
CHECKLISTThe compliance-to-trade checklist
The registrations you cannot trade without, each with its official route. A signpost, not legal advice.
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02 Step 02
Step 02
Get Client Money Protection membership
If you hold client money, CMP reimburses landlords, tenants and buyers if it is ever misappropriated. It has been mandatory for letting agents in England since April 2019, and non-compliance can cost up to £30,000.
Do it yourself
- Confirm whether you will hold client money (see Money & Client Accounts in Module 2).
- If you handle client money you must have CMP: letting agents always, and sales-only agents that hold client money too.
- Join an approved scheme: Propertymark CMP, Client Money Protect, UKALA, RICS or Safe Agent.
- Get the prerequisites ready: a proper client account, professional indemnity cover, and transparent client accounting.
- Display your CMP certificate.
Common mistake · Believing CMP is only for big firms. A one-person letting agency holding a single deposit needs it just as much.
Time~1–2 hours CostFrom ~£300–£600+/yr depending on scheme and turnover (indicative; confirm live figures on the scheme site) DifficultyEasy–Medium -
03 Step 03
Step 03
Register for AML supervision with HMRC
Estate agency businesses must be supervised by HMRC for anti-money-laundering and must do customer due diligence. HMRC actively fines and names agents who are not registered.
Do it yourself
- Register the business for money-laundering supervision on GOV.UK (letting agency businesses register too where rents meet the threshold).
- Budget the current fees: as updated on 1 December 2025, a £300 one-off non-refundable registration fee, £400 per premises each year, and a £40 approval fee per beneficial owner, officer or manager. A small-business reduction exists for very low turnover, so verify the live figures on GOV.UK.
- Appoint a nominated officer (MLRO) and write a proportionate AML policy and risk assessment.
- Build your customer due diligence routine: verify the seller or landlord at instruction, the buyer at offer, and report suspicious activity through a SAR.
Common mistake · Treating AML as a one-off registration and skipping the ongoing ID checks and record-keeping. That is exactly what HMRC penalises.
Time~half a day CostFees as above (verify live figures on GOV.UK) DifficultyMedium -
04 Step 04
Step 04
Register with the ICO and pay the data protection fee
You handle large volumes of personal data, so you must pay the ICO data protection fee and comply with UK GDPR.
Do it yourself
- Pay the ICO data protection fee: for a small agency this is normally Tier 1 at £52/yr or Tier 2 at £78/yr (rates from February 2025, with a £5 discount for direct debit).
- Publish a privacy notice on your website.
- Set basic data hygiene: a secure CRM, access control, and a clear retention approach.
- Be ready to handle data-subject requests.
Common mistake · Skipping ICO registration as "just a small fee". It is a legal duty, and not registering is itself an offence.
Time~30 minutes Cost£52–£78/yr (confirm the current fee on ico.org.uk) DifficultyEasy -
05 Step 05
Step 05
Master material information and the DMCC Act 2024
Since 6 April 2025 the DMCC Act has replaced the old consumer protection rules, and the CMA now enforces them directly. Leaving material information out of a listing is an unfair practice, with severe penalties.
Do it yourself
- Learn the framework, still the working standard: Part A is price and tenure (price, freehold or leasehold, council tax band); Part B is physical characteristics (property type, construction, services, parking); Part C is anything that could affect a decision (flood risk, restrictive covenants, planning issues, non-standard construction).
- Build a standard listing data-capture form so every property is worked up the same way before it goes live.
- Note where things stand: NTSELAT withdrew its detailed material-information guidance on 9 May 2025, but the duty to disclose remains.
- Keep a record of what you disclosed, and when, for each listing.
Common mistake · Reverting to highlights-only marketing after the NTSELAT guidance was withdrawn. The legal duty to disclose material information did not go away.
Time~half a day CostFree DifficultyMediumResource for this step
PDFMaterial information capture form
A per-property form covering Part A, B and C, filled in before a listing goes live. Reflects the current framework; not legal advice.
What you’ll have after this stage
- Membership of an approved redress scheme
- Client Money Protection cover, if you hold client money
- HMRC anti-money-laundering supervision and a due-diligence routine
- Your ICO fee paid and a privacy notice published
- A material-information capture form for every listing