If your business buys alcohol from a UK wholesaler and sells it on to customers, you are legally required to check that the wholesaler is approved under the Alcohol Wholesaler Registration Scheme (AWRS) before purchase. That duty sits with the buyer, not just the seller. Failing to check, or buying from an unapproved source, breaches AWRS due-diligence requirements and puts the business at risk of penalties and stock action by HMRC.
This guide explains the register-vs-check split, walks through the URN verification process, covers the records to keep, and flags where AWRS compliance sits in your purchase bookkeeping.
The short answer: buying alcohol for resale means you must check your wholesaler is AWRS-approved
Any business buying alcoholic stock from a UK wholesaler for resale must verify that the wholesaler holds HMRC approval under AWRS before placing the order, and must repeat this check regularly, keeping records as evidence of due diligence. The wholesaler's Unique Reference Number (URN) is the confirmation to request and record.
This is a buyer duty, not a buyer registration. The pub, restaurant or bar does not join AWRS; the wholesaler does. The buyer's obligation is to check and document.
Who must register for AWRS, and who must check
The two groups have different obligations under the scheme. Confusing them is the most common mistake operators make when this topic comes up.
| Your role | What you do with alcohol | Your AWRS obligation |
|---|---|---|
| Wholesaler / cash-and-carry | Sell alcohol to other businesses for resale | Must register with HMRC and obtain approval before trading. Must display URN. |
| Pub, bar, restaurant, off-licence | Buy alcohol from a wholesaler and sell it to the public | Must verify the wholesaler's URN before purchase and keep records. No registration required. |
A wholesaler trading without HMRC approval faces penalties under the scheme. The buyer who purchases from that unapproved wholesaler also faces consequences, even if unaware of the breach, because the buyer has failed the due-diligence check they are required to carry out.
Manufacturers and producers selling directly to the public (for example, a brewery taproom selling cans to walk-in customers) operate under a different set of excise approvals and are not covered by this guide; the AWRS buyer-check obligation applies to purchases from the UK wholesale supply chain.
How to verify a wholesaler's AWRS number (URN) using the online lookup
HMRC operates an online lookup service where any buyer can search for a wholesaler by name or URN to confirm approval status. The service is linked from the main AWRS guidance page on GOV.UK.
The check before a first order involves three steps:
- Ask the wholesaler for their URN. Any approved wholesaler should be able to provide it immediately. Reluctance or inability to produce a URN is a warning sign.
- Run the URN through the HMRC online AWRS service. Confirm the name matches the supplier you are dealing with and that the status is shown as approved.
- Record the result before the order goes in. Note the URN, the date, and what the lookup showed. File this with the purchase order or the first invoice from that supplier.
Do not rely on a previous check you ran months earlier. Status can change: an approved wholesaler can have approval revoked. Re-check at a frequency that reflects how often you buy from that supplier.
How often to re-check, and the records to keep as due-diligence evidence
HMRC requires buyers to repeat the check regularly. The guidance does not prescribe a fixed interval (monthly, quarterly, annual). In practice, the sensible approach is to tie re-checks to your ordering cadence with each supplier.
A minimal due-diligence record for each wholesaler looks like this:
| Record | Detail to capture |
|---|---|
| Wholesaler name | Exact legal trading name as shown on HMRC's lookup |
| URN | The Unique Reference Number provided and confirmed |
| Check date | The date you ran the HMRC lookup |
| Result | "Approved" or any other status shown |
| Checked by | The staff member who ran the check |
| Next scheduled re-check | Date set in the diary or ordering calendar |
If HMRC investigates a purchase and the buyer cannot produce evidence that they checked, the due-diligence defence falls away. The record is the defence.
What happens if you buy from an unapproved wholesaler
Purchasing alcohol for resale from a wholesaler who is not HMRC-approved breaches AWRS due-diligence requirements. HMRC has powers under the scheme to impose penalties and to seize stock connected to unapproved trading. HMRC's AWRS guidance sets out the enforcement framework; no fixed penalty schedule is published on the face of the guidance, and the consequences depend on the circumstances of the breach.
The key practical points for an operator are:
- Ignorance of the wholesaler's status is not a complete defence if the buyer failed to check.
- Stock purchased from an unapproved source can be subject to seizure, which means lost product on top of any penalty.
- An unapproved wholesaler is more likely to be trading illicit or duty-unpaid alcohol, which creates additional exposure for the buyer's licensing position.
- A licensing authority reviewing a licence can take into account compliance failures including AWRS breaches.
The risk is not abstract. HMRC runs AWRS compliance operations, particularly in the licensed trade, where duty fraud in the alcohol supply chain is a documented enforcement priority.
AWRS and your bookkeeping: keeping supplier evidence with purchase records
AWRS compliance sits naturally alongside your purchase ledger. Every alcohol purchase should be supported by:
- The supplier invoice (VAT-valid, showing the supplier's name and address).
- A delivery note or goods received record.
- The AWRS check record for that supplier (URN, date, result).
If your bookkeeping is done in a cloud accounting package, the simplest approach is to attach the AWRS check record as a document against the supplier contact record, and update it each time you re-check. That way the evidence is retrievable if HMRC or your accountant needs it during a review.
Operators on the VAT Flat Rate Scheme should also ensure their alcohol purchases are captured correctly; alcohol is standard-rated at every point in the supply chain (see HP 3 on zero-rating carve-outs), so purchase invoices should always show 20% input VAT from a UK supplier.
If you run a pub or bar with multiple alcohol suppliers, a simple supplier register maintained in a spreadsheet or attached to your accounts file handles the compliance record for all of them. Draught products from a different wholesaler to packaged goods is a common setup; each wholesaler needs its own URN check log. For more on how alcohol duty rates differ between draught and packaged products, see the draught relief explained guide.
Getting your licensed-trade compliance in order
AWRS checks are one layer of a broader compliance picture for licensed operators. A premises licence (and a designated premises supervisor holding a personal licence) is the foundation for selling alcohol legally in England and Wales. Gaming machines require Machine Games Duty registration before they go live. And from April 2026, sole-trader operators above the income threshold are in scope for Making Tax Digital for Income Tax.
For operators who want a single point of contact for licensed-trade accounts, payroll, and VAT, the pubs and bars hub sets out how we work with licensed premises. AWRS record-keeping, purchase ledger reconciliation, and annual compliance reviews can all sit within a managed accounts service so that nothing falls through the gaps between an HMRC visit and your year-end.