AWRS Due Diligence — Are You Actually Keeping Up With Your Checks?

If your business buys alcohol from a UK wholesaler to sell on, you have a legal obligation to verify that wholesaler’s AWRS registration. Most operators know this. What most operators don’t do is check regularly — or keep any evidence that they checked at all.

A Quick Recap on AWRS

The Alcohol Wholesaler Registration Scheme was introduced by HMRC in 2016, with enforcement for trade buyers beginning in April 2017. The scheme requires all UK businesses that sell alcohol wholesale to register with HMRC and obtain a Unique Reference Number (URN). HMRC estimated that alcohol duty fraud was costing the UK economy over £1.3 billion per year — the AWRS was their response.

So: if you buy alcohol from a wholesaler, you need to check that wholesaler is on the register. That’s the law.

What Does HMRC Actually Require?

HMRC’s published guidance on the scheme sets out four things you must do:

1. Request your wholesaler’s Unique Reference Number (URN)
2. Check that URN to confirm the supplier holds a valid AWRS registration
3. Periodically refresh those checks to ensure the wholesaler’s approval remains valid
4. Keep records of these checks as evidence of your due diligence

That fourth point is the one most businesses miss. It’s not enough to check — you need to be able to prove you checked.

NB: HMRC does not prescribe a specific method for carrying out these checks. There is no required format, no mandated software, no particular document you must produce. The requirement is that you can demonstrate you did the checks and did them regularly.

The Problem

In practice, most operators either checked their suppliers once — perhaps when AWRS came into force — and haven’t looked at it since, or they’ve never checked at all.

Both positions carry risk. A supplier’s AWRS status can change at any time. HMRC can revoke a registration if the business no longer meets the “fit and proper” criteria. The penalties are serious: civil penalties of up to £10,000 per offence, seizure of alcohol stock, and in serious cases, criminal prosecution — even if the alcohol has had duty fully paid.

For a pub group with 20, 30, or 50 suppliers across multiple sites, manually checking each one on GOV.UK every quarter and keeping those screenshots organised for up to 6 years is the kind of task that starts well and quietly stops happening. Staff change. Folders get lost. Nobody remembers whose job it was.

A Tool Built for This Problem

AWRSCheck (awrscheck.co.uk) is a tool built specifically for AWRS supplier verification and record-keeping.

Checking your suppliers

You add your suppliers to a dashboard — name and URN — and check them against HMRC’s register. The result comes back instantly: approved or not approved. You can add as many suppliers as you like, check as often as you like, and your full check history is visible in the app. This is free, and it stays free.

The audit trail — Pro tier at £19.99/month or £199/year (saving 2 months)

The Pro tier is for operators who need verified records and automation:

• PDF compliance certificates for every check, with cryptographic integrity verification — meaning the document can be independently verified as unaltered after it was created
• A 6-year compliance vault — every record timestamped and securely stored, retrievable for any audit or inspection
• Scheduled automated checks — weekly or monthly, so the checks happen whether you remember or not
• Email alerts if a supplier’s AWRS status changes
• Bulk CSV import and exportable compliance reports for auditors or head office

All new accounts receive a 14-day trial of the Pro features, no payment details required.

Who Is This Actually For?

If you’re a single-site pub with three or four regular suppliers, the manual GOV.UK process is perfectly adequate.

Where AWRSCheck comes into its own is for multi-site operators — pub groups, restaurant chains, hotel groups — where the supplier list is long and the person doing the checking is already juggling other compliance responsibilities. It’s also useful for wholesalers and distributors who need to verify their own supply chain.

Offer for Readers of The Licensing Guys™

Sign up here and receive 3 months of Pro access at no cost. No payment details required to start.

Whether you use AWRSCheck or stick with the manual approach, the important thing is that you are checking your suppliers regularly and that you can produce evidence if HMRC asks for it. That’s been the law since 2017 — and it’s not going away.