The UK’s alcohol industry is tightly regulated to prevent tax evasion, fraud, and the sale of illicit alcohol. One of the most important requirements for anyone involved in the wholesale of duty-paid alcohol is completing the Alcohol Wholesaler Registration Scheme Application (AWRS application). Whether you are launching a new wholesale business or adding alcohol wholesaling to your existing operations, understanding the process is essential.
1. Understanding the Alcohol Wholesaler Registration Scheme Application
1.1 What is it?
The Alcohol Wholesaler Registration Scheme Application is HMRC’s official process for registering any business that intends to trade in duty-paid alcohol at the wholesale level. It applies to UK-based companies, sole traders, partnerships, online sellers, and even businesses that import alcohol before selling it to other traders.
1.2 Why Matters
HMRC introduced AWRS to reduce alcohol duty fraud and ensure that only legitimate, compliant businesses enter the supply chain. Completing the it correctly gives you:
- A legal right to trade as a wholesaler
- An approval number required by your buyers
- The ability to supply retailers, pubs, restaurants, and other wholesalers
- Protection against criminal and financial penalties
No business can legally sell alcohol at the wholesale level without AWRS approval.
2. Who Needs to Submit an Application?
2.1 Businesses That Must Apply
You must complete an AWRS applicationif your business:
- Sells duty-paid alcohol to another business (not to consumers)
- Buys alcohol for onward sale in the UK
- Imports alcohol before selling it in the UK supply chain
- Stores alcohol for someone else and is involved in arranging wholesale transactions
2.2 Businesses That Do Not Need to Apply
Retailers that sell only to consumers—such as off-licenses, supermarkets, and restaurants—do not need to submit it unless they also make sales to other businesses.
3. Preparing for Your Alcohol Wholesaler Registration Scheme Application
Before starting the online form, gather the information HMRC will ask for. Preparation is crucial: many refusals happen because applicants underestimate how detailed the application needs to be.
3.1 Business Structure and Legal Documentation
Your application must include:
- Company registration certificates (if applicable)
- Details of all directors, partners, or persons with significant control
- Any relevant licences or previous registrations
If you are a sole trader, HMRC will still require personal identification and business information.
3.2 Evidence of Trade Viability
HMRC wants to ensure your business has legitimate commercial intentions. Your application should ideally be supported by:
- Supplier letters of intent or draft supply agreements
- Customer interest or purchase intentions
- Business plans demonstrating expected alcohol volumes
- Financial forecasts showing how you will fund the initial stock
3.3 Due Diligence Procedures
One of the most common reasons for AWRS refusal is inadequate due diligence. As part of your application, HMRC expects:
- A written due diligence policy
- Procedures for checking suppliers’ AWRS numbers
- Risk-assessment systems to identify illegitimate alcohol
- Records of how you verify invoices, transport documents, and payment methods
4. Completing the Alcohol Wholesaler Registration Scheme Application
4.1 Submitting Online Through HMRC’s System
Your application is submitted through the Government Gateway. Ensure you have a Government Gateway ID with the correct business tax services activated
The application includes:
- Business identity
- Premises information
- Expected trading activities
- Details of responsible individuals
- Financial background
- Due diligence evidence
4.2 Being Honest and Accurate
It is vital to be transparent. Providing outdated or inconsistent details is a common reason for an application to be flagged for further checks—or rejected.
HMRC may conduct background checks such as:
- Credit assessments
- Cross-checking director histories
- Reviewing VAT and corporation tax compliance
- Reviewing previous tax investigations
Be prepared to answer follow-up questions after submission.
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5. What Happens After application?
5.1 HMRC Review and Possible Visit
Once submitted, the application enters the review stage. HMRC may schedule:
- A phone interview
- A request for further documents
- A physical compliance visit
During a visit, HMRC will want to see:
- Your proposed storage facilities
- Your business documentation
- Your due diligence procedures in practice
5.2 Receiving Your AWRS Approval Number
If approved, you receive an AWRS Unique Reference Number (URN). You must display this number on invoices and provide it to your customers.
If your application is refused, HMRC will provide reasons and you may have the right to request a review or submit a new, improved application.
6. Avoiding Common Mistakes in the Alcohol Wholesaler Registration Scheme Application
6.1 Weak or Missing Due Diligence
The number-one failure point in an application is insufficient due diligence. HMRC expects your due diligence to include:
- Risk-rated supplier checks
- Verification of supply chain legitimacy
- Document retention procedures
- Fraud-prevention measures
6.2 Unrealistic Business Plans
If your financial forecasts or trading volumes appear unrealistic, HMRC may question the feasibility of your business. Your Alcohol Wholesaler Registration Scheme Application should be supported by evidence-based projections.
6.3 Lack of Premises or Storage Plans
HMRC will not approve an application unless you have identified where alcohol will be stored and how it will be secured. Even if you plan to store alcohol at a third-party bonded warehouse, you must provide written confirmation of arrangements.
6.4 Poor Record-Keeping Systems
During the review, HMRC expects evidence that your systems can track:
- Purchase records
- Customer records
- Delivery notes
- Payments
A vague or incomplete description in your application may raise red flags.
7. Tips for a Successful Alcohol Wholesaler Registration Scheme Application
7.1 Provide Clear, Organised Documentation
Organise your supporting documents into labelled, easy-to-understand files before attaching them to your application.
7.2 Demonstrate Your Industry Knowledge
HMRC wants reassurance that you understand your legal obligations. In your application, clearly outline:
- How you will check the legitimacy of every supplier
- How you will ensure your customers are licensed to trade
- How you will avoid trading in illicit alcohol
7.3 Keep Consistency Across All Business Records
Ensure consistency between:
- Companies House details
- Tax records
- Business plans
- Bank information
- Trading addresses
Inconsistencies cause delays or refusals.
7.4 Respond Quickly to HMRC Requests
If HMRC asks for additional information, respond quickly. Delays can stall or jeopardize your application.
8. Renewals and Ongoing Compliance After Approval
AWRS approval is not permanent. You must continue meeting HMRC standards. Renewals may require updated documents similar to your original Alcohol Wholesaler Registration Scheme Application.
Ongoing compliance obligations include:
- Annual return updates
- Maintaining due diligence records
- Keeping supplier AWRS numbers current
- Informing HMRC of business changes
Failure to comply can lead to the revocation of your AWRS URN.
Conclusion
The Alcohol Wholesaler Registration Scheme Application is a detailed and sometimes demanding process, but with proper preparation, clear documentation, and strong due diligence, it is completely manageable. Whether you are launching a new venture or expanding into alcohol wholesaling, understanding how to complete it will save you time, stress, and the risk of refusal.
By approaching the process methodically—gathering documents, preparing your business plan, implementing solid due diligence procedures, and responding promptly to HMRC—you will greatly improve your chances of success and ensure your business enters the alcohol supply chain legally and confidently. WellTax has the experience to support you throughout the process. You can see more about the services we offer here.