HMRC investigations: what triggers one and how naming works

What a compliance check is

HMRC uses the term compliance check for its enquiries into a taxpayer's return or tax position. The word investigation is common in everyday use, but the formal term is compliance check, and the letter you receive will use that language. A check can cover a tax return, accounts, a VAT position, PAYE, or simply whether the right tax has been paid. The letter states what HMRC is checking, so the scope is set out on the page in front of you rather than left open.

The practical first steps are straightforward. Read what is actually being asked, rather than what you assume is being asked, and note the deadline stated in the letter. Keep everything in writing, because a written record of what was asked and what was provided is easier to rely on later than a recollection of a phone call. Consider getting an accountant or tax adviser involved early rather than after a position has been taken, since an adviser cannot change the facts but can affect how a disclosure is presented and therefore the reduction earned.

How penalties are decided

Two things set a penalty: the behaviour and the disclosure. Behaviour runs from a mistake despite taking reasonable care, through careless, to deliberate, to deliberate and concealed, with the penalty range rising at each step. A mistake despite reasonable care sits at the lowest end. Careless behaviour sits above it. Deliberate behaviour sits above that, and deliberate and concealed behaviour sits at the top of the range. The category that applies to your case is the single largest driver of the penalty range.

Disclosure is either unprompted or prompted. A disclosure is unprompted if it is made at a time when you had no reason to believe HMRC had discovered or was about to discover the inaccuracy. Otherwise it is prompted, and unprompted disclosures attract larger reductions. The quality of a disclosure is assessed on telling HMRC about the inaccuracy, helping HMRC work out what is owed, and giving HMRC access to records. An unprompted full disclosure attracts the largest reduction available, and that reduction matters twice over, because it lowers the penalty and it prevents publication of your details.

When HMRC can publish your name

The law allowing publication is section 94 of the Finance Act 2009, and HMRC has published details of deliberate tax defaulters since 1 April 2010. HMRC may publish information about a deliberate tax defaulter where it has carried out an investigation, the person has been charged one or more penalties for deliberate defaults, and those penalties involve tax of more than 25,000 pounds. The conditions are cumulative, and the table below sets them out.

A person's information will not be published if they earn the maximum reduction of the penalties by fully disclosing details of the defaults. This is the single most important consequence of disclosing fully, because it changes not only the size of the penalty but whether the person is named at all. Information is published once the penalties are final. A penalty becomes final on the day after the end of the appeal period if the person does not appeal, the date when an appeal is finally determined, or the date when a contract settlement is made.

What gets published, and for how long

HMRC publishes enough information to identify the deliberate tax defaulter, the penalties imposed for their deliberate defaults, and the amount of tax on which those penalties are charged. The list is published as a spreadsheet on GOV.UK, and from June 2026 the list of deliberate tax defaulters is published as an ODS spreadsheet file. The current list of deliberate tax defaulters was published on 25 June 2026 and covers details up to March 2026, so the published list is a snapshot rather than a live record.

The law requires HMRC not to publish any information about the person for more than 12 months from the date it first publishes it, so details are removed within 12 months of first publication. The lists of deliberate tax defaulters are not captured for The National Archives, so an entry does not remain a permanent public record in that archive. That does not make an entry invisible while it is live, but it does mean the entry has a defined end point rather than an indefinite one.

If you disagree with HMRC

There are routes and an order to them. A taxpayer who disagrees with an HMRC decision can appeal to HMRC, ask for a review by an officer not previously involved, or appeal to the independent tax tribunal, within the time limit stated in the decision letter. Asking HMRC to look at the decision again is often the first step, and a review by an officer not involved in the original decision is a separate option. The independent tax tribunal is the route outside HMRC itself.

A penalty is not final while an appeal is live, which matters because publication only follows a final penalty. Time limits are short and are stated in the letter, so the date in the letter is the date to work to. If you are unsure which route applies to your letter, an accountant or tax adviser can explain the options and the deadlines, and TaxAid provides free tax advice to people on low incomes who cannot afford professional help.

Where to get help

For anything substantial, a chartered accountant or chartered tax adviser is the practical starting point. An adviser cannot change the facts, but can affect how a disclosure is presented and therefore the reduction earned, which in turn affects both the penalty and whether publication follows. Early involvement is generally more useful than late involvement, because the presentation of a disclosure is easier to shape before a position has been taken.

TaxAid is a charity providing free tax advice to people on low incomes who cannot afford professional help. The Contractual Disclosure Facility is HMRC's formal route for a person who wants to admit deliberate tax fraud, and it is a formal route with its own rules, so it is worth taking advice before using it. This guide is general information rather than tax advice on a specific situation, and it does not estimate anyone's chance of being investigated.

Source: GOV.UK: details of deliberate tax defaulters.

Related coverage on Kael Tripton: HMRC Time to Pay: how to spread a tax bill you cannot pay, UK Fines and Enforcement Ledger: FCA, ICO, Ofgem, HMRC, Self Assessment: register by 5 October or face a penalty, HMRC July 2026 Self Assessment Deadline: Second Payment on Account Due 31 July, Self Assessment Tax Return UK 2025/26: Deadlines, Who Must File and How to Submit.

Frequently asked questions

What is the difference between a compliance check and an investigation?

HMRC uses the term compliance check for its enquiries into a taxpayer's return or tax position. A check can cover a tax return, accounts, a VAT position, PAYE, or whether the right tax has been paid, and HMRC writes to say what it is checking.

When can HMRC publish the name of a deliberate tax defaulter?

HMRC may publish information about a deliberate tax defaulter where it has carried out an investigation, the person has been charged one or more penalties for deliberate defaults, and those penalties involve tax of more than 25,000 pounds. The penalties must also be final before publication.

Can full disclosure prevent publication?

A person's information will not be published if they earn the maximum reduction of the penalties by fully disclosing details of the defaults. An unprompted full disclosure attracts the largest reduction, and the quality of a disclosure is assessed on telling HMRC about the inaccuracy, helping HMRC work out what is owed, and giving HMRC access to records.

How long do published details stay online?

The law requires HMRC not to publish any information about the person for more than 12 months from the date it first publishes it. The lists of deliberate tax defaulters are not captured for The National Archives.

What can you do if you disagree with an HMRC decision?

A taxpayer who disagrees with an HMRC decision can appeal to HMRC, ask for a review by an officer not previously involved, or appeal to the independent tax tribunal, within the time limit stated in the decision letter. A penalty is not final while an appeal is live.