The Chartered Institute of Taxation (CIOT) has warned that the government’s draft legislation intended to curb rogue tax agents and promoters of tax avoidance schemes risks missing their target while burdening compliant advisers. In a letter to Exchequer Secretary to the Treasury Dan Tomlinson, CIOT supported efforts to raise standards in the tax advice market but noted that the draft Finance Bill 2025–26 measures on adviser penalties, mandatory registration and marketed avoidance schemes are poorly targeted. It cautioned that where tax law is unclear or potential liabilities are high, reputable advisers may withdraw from giving advice for fear that honest guidance could trigger severe penalties or criminal charges, reducing taxpayer access to services and widening the tax gap. CIOT Director of Public Policy, Ellen Milner, noted that while action against mass-marketed avoidance schemes is justified, the proposals would likely fail to capture the roughly 20 overseas operators dominating the market and could have a ‘chilling effect’ on legitimate advice. CIOT added that mandatory registration is unlikely to identify true promoters of tax avoidance and urged the government to delay implementation, working with stakeholders to produce more practical legislation, including deferring the registration requirement until April 2027.