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Alcohol Wholesale Registration Scheme

We are able to advise and act for you in connection with The Alcohol Wholesaler Registration Scheme, which started on the 1st October 2015, and your application to register as a trader. We will assist you satisfying HMRC that you are a ‘fit and proper’ person.

We can also act in any issues that arise, or appeal the Refusal.  If your business is at risk, we can advise and act on an Appeal to the First Tier Tax Tribunal and a Judicial Review and Injunction proceedings.  We will also address any threats to seize your stock.

The application needed to be made between 1st October and 31st December and all wholesalers needed to apply, including those who held excise approvals – if this was complied with then you could continue trading until the outcome was determined.

The types of businesses affected are:

  • Alcohol wholesalers
  • Brokers
  • Auctioneers
  • Alcohol retailers


The scheme does not apply to private individuals purchasing alcohol from retailers.

With an estimated 20,000 traders applying it is a lengthy process – HMRC gave an undertaking that all cases would be determined by 1st April 2017.  From 1st January 2017 it’s been a criminal offence for businesses to purchase alcohol from an unapproved UK wholesaler if the buyer knew, or who had reasonable grounds to believe the seller was not approved.

HMRC provide an online service that allows trade buyers to verify that wholesalers have the correct licence.

Key issues being considered by HMRC prior to approval are:

  • If directors and senior personnel have previously been involved with revenue non-compliance
  • Issues with invoices from suppliers and being able trace the stock back to a duty point
  • Issues with the level of due diligence and a reliance on website checks.

Companies and small businesses face having their licence refused and have the threat of their stock seized if this happens.

We are happy to meet HMRC and deal with any cases throughout the UK.
Contact Peter Hastings on ph@rogers-norton.co.uk or call 01603 675639 

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