AWRS Compliance Guide 2026: What Every UK Alcohol Retailer Needs to Know

What is the AWRS?

The Alcohol Wholesaler Registration Scheme (AWRS) was introduced by HMRC in 2016 to combat alcohol fraud in the UK. HMRC has estimated that alcohol fraud costs the UK taxpayer over a billion pounds each year in lost duty and VAT revenue. The scheme requires all UK businesses that sell alcohol to other businesses (wholesalers, distributors, importers) to register with HMRC and obtain a Unique Reference Number (URN).

From April 2017, trade buyers — meaning any business that buys alcohol from a UK wholesaler for resale — became legally required to verify that their suppliers hold a valid AWRS registration before purchasing from them.

The URN is a combination of four letters and eleven numbers, and it should appear on every wholesale alcohol invoice. You can verify any URN using HMRC's online look-up service.

Who needs to check their suppliers?

If your business buys alcohol from a UK wholesaler for onward sale or supply, you need to check your suppliers. This applies to a wide range of businesses including pubs, bars, and pub groups; restaurants and restaurant chains; hotels and hotel groups; nightclubs and entertainment venues; off-licences and convenience store groups; catering companies and event caterers; theatres, cinemas, and stadiums; and wholesalers buying from other wholesalers.

There are a few exemptions. You do not need to check if you are an individual buying alcohol for a one-off personal event, or if you are a retailer making only occasional, unplanned wholesale sales (for example, a shop selling a case of wine to a local restaurant that has run out). However, if you regularly buy alcohol from wholesalers for your business, the requirement applies to you.

How to check an AWRS number

Checking a supplier's AWRS registration is straightforward but manual. Here is the process:

Step 1: Find the URN

Look for the supplier's Unique Reference Number (URN) on their invoices. It should be printed on every wholesale alcohol invoice. If you cannot find it, contact the supplier directly and ask them for it. A legitimate, registered wholesaler will have no issue providing this.

Step 2: Verify on GOV.UK

Go to the HMRC AWRS look-up service. Enter the URN. The service will return the wholesaler's approval status, registration date, business name, trading name, and principal place of business. If the URN is not found or the status is not "Approved," you should not purchase alcohol from that supplier.

Step 3: Save the evidence

HMRC advises you to keep a record of your check by printing off or saving the results page. This is your evidence of due diligence. You will need to keep these records in case HMRC asks to see them.

Record-keeping requirements

HMRC requires you to keep records of your AWRS checks as evidence of your due diligence activities. While HMRC does not specify an exact format, your records should include the date you performed the check, the supplier's URN, the result of the check (approved or not), and the supplier's business name and trading name as shown in the results.

Although HMRC does not explicitly state a retention period specifically for AWRS check records, standard HMRC record-keeping requirements for businesses typically require records to be kept for 6 years. Keeping your AWRS records for 6 years is considered best practice and is the standard recommendation from compliance advisors.

Most businesses store these records as screenshots, printed pages, or saved PDFs. The challenge is that over time, with multiple suppliers and quarterly checks, this becomes a significant volume of records to organise and maintain.

Penalties for non-compliance

The penalties for failing to comply with the AWRS are serious. According to HMRC guidance and relevant legislation, businesses found buying alcohol from an unapproved UK wholesaler can face civil penalties of up to £10,000 per offence, criminal prosecution with imprisonment of up to 7 years, seizure of alcohol stock by HMRC (whether or not duty has been paid), and loss of the right to sell alcohol.

These penalties apply both to wholesalers who trade without AWRS approval and to trade buyers who purchase from unapproved wholesalers. The intent of the scheme is to ensure that every link in the alcohol supply chain is legitimate.

How often should you check?

HMRC uses the word "regularly" without defining a specific frequency. This is deliberately vague, and it means the appropriate frequency depends on your circumstances. However, most compliance advisors and industry bodies recommend the following as a reasonable approach.

At a minimum, you should check before your first purchase from any new supplier. After that, quarterly checks (every 3 months) are widely considered the baseline for demonstrating reasonable due diligence. Businesses in higher-risk environments, such as those buying from many small or new suppliers, may want to check monthly. Some businesses check before every purchase, though this is only practical if you have a small number of suppliers.

The key principle is that your checking frequency should be proportionate to your risk. A pub group buying from the same five major distributors faces different risks than an importer working with dozens of smaller suppliers.

How businesses currently handle AWRS checks

In practice, AWRS compliance varies significantly from business to business. Having looked at how companies across the UK approach this, a few common patterns emerge.

The manual approach

The most common method is straightforward: someone in the business goes to the GOV.UK look-up service, enters each supplier's URN one at a time, and either screenshots or prints the results page. These are then saved to a shared drive, a folder on someone's laptop, or in some cases, printed and filed physically. For a business with 5-10 suppliers checking quarterly, this takes around 30-60 minutes per cycle and produces a manageable number of records.

The problem arises as the number of suppliers grows. A pub group with 25-40 suppliers checking quarterly is performing 100-160 individual checks per year. Each one needs to be manually completed, recorded, named, filed, and retained for up to 6 years.

Spreadsheets and internal systems

Some businesses track their due diligence using spreadsheets — logging URNs, check dates, and results in Excel. A few trade associations have developed their own spreadsheet tools for members that can batch-check multiple URNs at once. These are a step up from the fully manual approach, but they still require someone to run the checks, update the records, and manage the filing.

Others integrate AWRS checking into their broader due diligence process. Several alcohol wholesalers and distributors publish detailed Due Diligence Codes of Conduct (DDCOCs) that cover AWRS alongside other checks like company verification, VAT status, and risk assessment. In these businesses, check reminders are typically logged in CRM software, accounting tools, or internal calendar systems, with a designated person responsible for the sign-off process.

The gap

What most of these approaches share is that they rely heavily on a specific person remembering to do the checks, manually completing them, and properly filing the records. If that person leaves, gets busy, or simply forgets a quarter, the business can fall out of compliance without realising it — and there's no system to catch the gap. For businesses with anything more than a handful of suppliers, this is a real operational risk.

Common compliance mistakes

Based on HMRC guidance and industry feedback, these are the most common mistakes businesses make with AWRS compliance.

Checking once and never again

A supplier's AWRS status can change. Registrations can be revoked if HMRC finds the business no longer meets the "fit and proper person" criteria. Checking once when you first start buying from a supplier is not sufficient — you need to re-check periodically.

Not keeping records of checks

Performing the check is only half the obligation. You also need to keep evidence that you performed it. If HMRC audits your business and you cannot produce records of your checks, you have no proof of due diligence even if you did check at the time.

Relying on the supplier to prove their own registration

While suppliers should display their URN on invoices, the legal obligation to verify is on you as the buyer. A supplier telling you "we're registered" is not the same as you independently verifying their URN through HMRC's look-up service.

Not checking all suppliers

The requirement applies to every UK wholesaler you buy alcohol from, not just your main suppliers. If you occasionally buy from a smaller or local supplier, they need to be checked too.

Losing records when staff change

When the person responsible for AWRS checks leaves the business, their records often go with them — saved on their laptop, in their email, or in a folder only they knew about. Without a centralised system, years of compliance records can effectively disappear overnight.

Automating your AWRS compliance

For businesses with a handful of suppliers, the manual GOV.UK process is manageable. But as the number of suppliers grows beyond 10-15, the combination of regular checks, record-keeping, and 6-year retention becomes a genuine operational burden — one that typically falls on an already-busy operations or compliance manager.

Despite this being a legal requirement since 2017, there is currently no widely available software product designed specifically for ongoing AWRS supplier verification. Some trade associations offer spreadsheet-based tools for their members, and larger enterprises may incorporate AWRS checks into broader compliance platforms. But for the thousands of independent pub groups, restaurant chains, hotel groups, and hospitality businesses in between, the options have been limited to the manual process or home-grown spreadsheets.

This is exactly why we're building AWRSCheck. It's a purpose-built tool for automating AWRS supplier verification: you add your suppliers, set a checking schedule (daily, weekly, monthly, or quarterly), and the system handles the rest. Every check is verified against HMRC's register, generates an integrity-checked PDF record, and is stored securely for the full 6-year retention period. If a supplier's status changes, you get an alert immediately.

Pricing starts at £4.99/month plus £1.50 per check, capped at a maximum of £49/month regardless of how many checks you run (up to 100). Every customer gets every feature — there are no tiers or gated functionality.

We're launching soon. If you'd like to be first in line, you can join the early access list — early members will receive a 14-day free trial with 10 free checks, no credit card required.

Sources

• GOV.UK — The Alcohol Wholesaler Registration Scheme (AWRS)
• GOV.UK — Check if an alcohol wholesaler is approved
• GOV.UK — Register as an alcohol wholesaler or producer
• Brodies LLP — The Alcohol Wholesaler Registration Scheme (AWRS)
• Business Gateway — Alcohol Wholesaler Registration Scheme
• Institute of Alcohol Studies — The alcohol industry: an overview