AWRS Explained: Is Your Alcohol Business Ready for HMRC?
- Simon Francis
- Jul 27
- 3 min read
If your business sells alcohol to other businesses—or purchases alcohol from UK wholesalers—the Alcohol Wholesaler Registration Scheme (AWRS) may apply to you.
Failing to understand your responsibilities could expose your business to enforcement action, financial penalties, seizure of alcohol stock and possible licensing consequences.
Watch: AWRS Explained
What is AWRS?
The Alcohol Wholesaler Registration Scheme is administered by HM Revenue and Customs.
It was introduced to combat alcohol fraud and prevent illegitimate alcohol from entering the UK supply chain.
Businesses selling or arranging the sale of duty-paid alcohol to other businesses for resale may need HMRC approval before beginning wholesale trading.
This can include:
Alcohol wholesalers and cash-and-carry businesses
Wine importers and specialist wine wholesalers
Breweries, vineyards, cider producers and distilleries
Brokers and auctioneers
Retailers regularly selling alcohol to other businesses
Other businesses supplying alcohol for onward sale
Some exclusions may apply, including certain exceptional or incidental wholesale sales.
When must a new wholesaler apply?
A new business intending to wholesale alcohol must normally apply for AWRS approval at least 45 calendar days before it intends to start trading.
The business must receive HMRC approval before wholesale trading begins. Submitting an application does not automatically provide permission to trade.
What could HMRC examine?
An AWRS application may require information about:
The business and its ownership
Directors, partners or responsible individuals
Business premises and storage arrangements
Products being supplied
Expected customers and suppliers
Ordering, invoicing and payment arrangements
Financial forecasts and business planning
Due-diligence procedures
Record-keeping arrangements
Measures used to identify and manage fraud risks
Incomplete or inconsistent information could delay the application or lead to additional questions from HMRC.
Your due-diligence responsibilities
AWRS compliance does not finish when approval is granted.
Wholesalers should have proportionate procedures for checking the businesses with which they trade.
These checks could include:
Confirming business identities and addresses
Checking company and VAT information
Verifying bank and payment details
Reviewing licences and registrations
Checking AWRS approval
Assessing unusually low prices
Investigating unexpected payment arrangements
Keeping evidence of completed checks
Reviewing suppliers and customers periodically
Staff must understand the procedures, apply them consistently and retain evidence.
Responsibilities of pubs, restaurants and retailers
Pubs, restaurants, hotels, clubs, shops and other businesses purchasing alcohol for resale should check that their applicable UK wholesalers are approved by HMRC.
The supplier’s AWRS Unique Reference Number should appear on wholesale alcohol invoices. Buyers can use the number to check the supplier through HMRC’s online service.
Checks should be repeated regularly, with evidence retained as part of the business’s due-diligence records.
Common AWRS compliance mistakes
Trading before HMRC approval is granted
Providing incomplete application information
Failing to check alcohol suppliers
Not retaining evidence of AWRS checks
Accepting unexplained cash or third-party payments
Ignoring commercially unrealistic prices
Using inadequate customer and supplier checks
Failing to update relevant business information
Having procedures that staff do not follow
Poor invoice, purchasing and stock records
Could AWRS affect a premises licence?
Purchasing alcohol from an unapproved wholesaler may have consequences beyond HMRC enforcement.
For licensed premises, unlawful or poorly controlled alcohol purchasing can raise concerns about the prevention of crime and disorder licensing objective.
Depending on the circumstances, this could contribute to enforcement action or a review of the premises licence.
Download the FREE AWRS Readiness Checklist
Use our free checklist to review your current arrangements and identify areas requiring further attention.
The checklist covers:
Business and application readiness
Supplier and customer checks
AWRS number verification
Due-diligence procedures
Invoices and record keeping
Payment controls
Staff responsibilities
Ongoing compliance reviews
DOWNLOAD YOUR FREE AWRS CHECKLIST
The checklist has been produced by Click2Comply as a practical compliance resource for alcohol businesses.
Need professional AWRS assistance?
Licensing Professionals can help businesses understand their responsibilities, prepare supporting information, review due-diligence arrangements and identify potential weaknesses before an application or HMRC enquiry.
The business itself must submit its AWRS application through its Government Gateway account.
Training and compliance resources: https://www.click2comply.co.uk
This article provides general information and does not constitute legal, financial or tax advice
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