From 25 November 2025, a targeted amendment to the Economic Crime (Anti‑Money Laundering) Levy Regulations 2022 confirms that HMRC, not the original regulator, must repay any overpaid levy once an FCA or Gambling Commission debt has been transferred to HMRC under regulation 25. The change is made by the Economic Crime (Anti‑Money Laundering) Levy (Amendment) Regulations 2025 (S.I. 2025/1146), as listed alongside other instruments on legislation.gov.uk–tracked services.

What changes operationally is simple: if an unpaid AML levy owed to the FCA or the Gambling Commission has been handed to HMRC for recovery, any later overpayment on that amount is now HMRC’s job to refund. That reflects how regulation 25 already allows the FCA or GC to transfer recovery functions to HMRC; HMRC’s own internal guidance also describes how such debts move across for enforcement.

For finance teams, this removes the risk of being bounced between collectors. The usual claim windows still apply. Under the 2022 Regulations, claims must be made within two years where the FCA is the collection authority and within four years where HMRC or the Gambling Commission is the authority. The rules also state that no interest is payable on repaid levy when the FCA or GC is the authority.

Quick refresher on who pays and how much. The levy applies to AML‑regulated entities with UK revenue above £10.2m, charged as fixed bands. Medium entities pay £10,000 and large entities £36,000. For very large entities, the charge rose from £250,000 to £500,000 for financial years from April 2024, via Finance (No. 2) Act 2024 amending section 54 of the Finance Act 2022.

Market Pulse UK view: treat this as a cashflow tidy‑up. Example: an FCA‑regulated payments firm with £36m–£1bn UK revenue pays the £36,000 levy late; the debt is transferred to HMRC, and the firm later discovers it paid twice. From 25 November, the refund request goes to HMRC, aligning the repayment with the body now holding the debt file and reducing admin friction.

Dual‑supervised groups should still check which body is their ‘appropriate collection authority’. HMRC’s guidance sets out the pecking order: FCA trumps HMRC, GC trumps HMRC, and GC trumps FCA where both apply. Once a debt moves to HMRC for recovery, the repayment route for any overpayment on that transferred amount is HMRC.

On process, keep claims clean. Regulation 19 requires claims to follow the form and information standards set by the relevant authority, including a declaration of completeness and accuracy. In practice, firms should line up revenue workings, payment evidence and any correspondence confirming a transfer under regulation 25 before submitting.

This is not a new charge, just clearer plumbing between regulators and the tax authority. For CFOs and heads of compliance, the action list is short: identify any AML levy balances that were transferred to HMRC; route any overpayment claims to HMRC from 25 November; and avoid duplicate claims to the FCA or GC. The underlying levy framework-set by the Finance Act 2022 and the 2022 Regulations-remains in place.