AWRS Application Process: From HMRC Form to Officer Interview

To get AWRS approval you apply online to HMRC at least 45 days before you start wholesaling alcohol, an HMRC officer then reviews your business against the fit and proper test, asks for documents and usually interviews you, and if satisfied issues the unique reference number you must show on your invoices. There is no fee. The whole process takes a minimum of 45 working days and the part that decides the outcome is the document pack and the interview, not the form.

This guide walks through the Alcohol Wholesaler Registration Scheme stage by stage, in the order HMRC actually runs it, and explains what the officer is looking for at each one. It is based on HMRC's AWRS guidance and on the applications we prepare.

Who needs AWRS approval

Any business in the UK that sells or supplies alcohol to another business for onward sale or supply: wholesalers, cash and carries, importers, brewers and distillers selling to the trade, online B2B sellers and brokers who arrange sales. The scheme covers alcohol on which UK duty has been paid; duty-suspended movements are handled under separate warehousing rules.

The AWRS application process, stage by stage

1. 1

   Apply online to HMRC

   The application is made through your Government Gateway business account, at least 45 days before you intend to start wholesaling. You describe the business, the people who run it, the premises, who you will buy from and sell to, and how you will check them. Nothing is sold to the trade until approval is granted.

2. 2

   HMRC acknowledges and allocates an officer

   Your application is given a reference and passed to an AWRS officer. The officer runs background checks on the company and its directors and key persons: HMRC compliance history, duty and VAT debts, previous involvement in failed or fraudulent businesses, and unspent convictions.

3. 3

   The officer requests documents

   Most applicants receive a written request for evidence, typically with a short deadline. The usual list: a business plan with forecasts, your due diligence policy and the checklist you use on suppliers and customers, lists of intended suppliers and customers with evidence of contact, premises and storage details, bank statements and accounts, insurance, and photo identification for each director.

4. 4

   Barnab drafts and assembles the pack

   This is where applications are won or lost. We draft the due diligence policy and checklist in the form HMRC officers expect, write or restructure the business plan around the supply chain questions the officer will ask, and organise every document folder by folder against the request so nothing is missing or contradictory. The pack goes back complete and in one submission.

5. 5

   The meeting with the HMRC officer

   Most applicants are interviewed, by phone, video call or a visit to the premises. The officer tests whether you understand the duty fraud risks in your supply chain and whether the controls in your policy are real: who checks a new supplier, what you do when a price looks too low, how you record it. We brief you on the questions beforehand so you answer from knowledge rather than memory of a document.

6. 6

   Decision and your unique reference number

   HMRC aims to decide within 45 working days of a complete application. On approval you receive your URN, your details appear on the AWRS online lookup so customers can verify you, and you must show the URN on every trade invoice. Approval does not expire but it can be revoked, and HMRC can impose conditions.

What the fit and proper test looks at

HMRC approves a business only if it is satisfied the business and the people behind it are fit and proper to wholesale alcohol. The factors it weighs, set out in its guidance, are:

• Whether the business, its directors or key persons have been involved in alcohol duty fraud or other significant revenue non-compliance
• Unspent criminal convictions relevant to the trade, including dishonesty and excise offences
• Outstanding HMRC debts or a history of failing to file returns and pay on time
• Involvement in businesses that have failed owing duty or VAT, or that have been refused or had approval revoked
• Whether you have adequate due diligence procedures to identify and avoid illicit supply chains, and whether you actually operate them
• Whether the business is commercially viable and the supply chain described is plausible
• Whether the premises, storage and record-keeping are adequate for the trade described

The document pack HMRC expects

After approval

Frequently asked questions

How long does AWRS approval take?

HMRC's published target is a decision within 45 working days of a complete application, and you must apply at least 45 days before you intend to start trading. An application that triggers a document request or a visit takes longer, which is why the pack should be ready before the officer asks for it.

Is there a fee for AWRS?

No. HMRC does not charge for an AWRS application or for approval. The cost is the time and the documents, and the agent's fee if you use one.

What does an AWRS number look like?

A unique reference number of 15 characters: two letters, then AW, then digits, for example XXAW00000123456. It is issued on approval and must be shown on every invoice for alcohol you sell to another business.

Do retailers need AWRS approval?

Not for selling to the public. A pub, shop or restaurant only needs AWRS approval if it also sells alcohol to other businesses for onward sale. Every trade buyer does, however, have to check that its wholesaler is approved, using HMRC's online lookup, and keep a record of the check.

What happens if HMRC refuses my AWRS application?

HMRC writes to explain the decision. You can ask for a review by an HMRC officer not involved in the original decision, and if the review upholds the refusal you can appeal to the tax tribunal. In practice most refusals come down to the fit and proper test or an incomplete picture of the supply chain, both of which are easier to fix before the decision than after.

Related: our AWRS registration service, and if you also sell to the public, the premises licence guide.