FOI release

Response to request for access to Council Tax database

Published 4 September 2025

FOI Request

“I would like to obtain access to the VOA Council Tax database – in particular the Address, Local Authority and Council Tax band for each property in England and Wales. Having checked what information is already in the public domain and for previous FOI requests it would appear that the information I wish to obtain is in the public domain and obtainable via www.gov.uk/council-tax-bands, however not to the extent that would enjoy an exemption by way of s.21 to the Freedom of Information Act 2000 [FOIA] because it is not in a form that reasonably accessible.

On looking for similar FOI requests [such as VOA References 11805830.1/CEO and 11806120.1/CEO], I have found several that you have responded to citing s.44(1)(a) FOIA and s.23(1) Commissioners for Revenue and Customs Act 2005 [CRCA’00]. However in order for this exemption to apply the information would have to enable information relating to a person to be disclosed.

Because the council tax banding of each individual property is already in the public domain, albeit not in an accessible form, it can not be within the scope of s.23(1) because for that to apply disclosure must be prohibited by s.18(1) CRCA’00. Disclosure can not however be prohibited because it has already been placed into the public domain.

If I am wrong, and s.18(1) applies, the prohibition in s.23(1) is further qualified that it shall only apply to information for which the disclosure:

“(a) would specify the identity of the person to whom the information relates, or

(b) would enable the identity of such a person to be deduced.”

It appears that in previous requests you have argued this applies to both individuals and legal entities – and I agree. However a property is not a legal entity but an asset who’s general characteristics are publicly available. Whist it is true that it may be possible to make links between properties and legal entities, the council tax band is not information about a person and any link drawn to a person from the data would be purely speculative.

And lets look carefully at the function of s.23(1)(a) and (b). (a) would only apply if the information relates to a person – which it does not because the information relates to a property. (b) would only apply if the information would enable the identity of such a person to be deduced – but if for example someone is to pair this data with Land Registry Title for a relevant property then the information tells us nothing more about the person listed in the Land Registry Title. We would already in that case be aware that they own a property but it would be pure speculation draw any further information from this pairing of data.”

Response

As required by section 1(1)(a) of the Act I confirm that we hold the information you have requested.

Section 44(1)(a) of the FOIA states we cannot provide the information because another Act prevents disclosure. Section 23(1) of the Commissioners for Revenue and Customs Act (CRCA) 2005 prevents disclosure in this case. 

Section 44 is an absolute exemption and so does not require consideration of a public interest test.  This means we cannot consider any benefit to the general public, including yourself that disclosing the information may bring.

Information is covered by section 23(1) CRCA when:

• Held for a function of HMRC - The VOA is an Executive Agency of HMRC. Our functions are identified in sections 7 and 10 of CRCA. The information you have requested is held for Council Tax purposes, one of the functions of the VOA.

• Relates to property where a person could be identified from the information - The term ‘person’ applies not just to individuals, but to any legal entity such as a company or partnership. The information you have requested is about properties identified by the addresses. There are many ways of linking addresses to people by cross referencing with other information available to the public. For example HM Land Registry, electoral registers, local library resources and other online information.

I have attached an appendix setting out the law, and an explanation of information we are unable to disclose under the FOIA.

Outside of FOIA (advice and assistance)

Provision of information outside of the FOIA

The response above explains that section 23(1) of CRCA prevents us from providing the information you have requested under the FOIA. Taxpayer confidentiality is a key concept of CRCA and disclosure of data or information is only allowed in certain, limited circumstances; including to perform a function of VOA and where another law allows disclosure. 

This means there is also no lawful basis within CRCA for VOA to provide the information you seek outside of the FOIA. This may appear a surprising outcome when the information sought is readily available at individual record level (for England and Wales) through the www.gov.uk website but the logic is outlined below:

1. The VOA publishes the Council Tax Lists to give taxpayers access to the banding of their property and those of others nearby for comparison. The list includes information linked to a person, through the address, which is collected for this function of VOA.

2. The VOA compiles the Lists under the Local Government Finance Act (LGFA) 1992, which also requires us to make information about these Lists available to the public. Section 28 LGFA 1992 empowers the VOA to choose a suitable format, and the VOA web application is designed to allow self-service access. The need for disclosure for that purpose is fully satisfied by our web application.

3. Bulk disclosure is not necessary to satisfy the requirements of section 28 LGFA, nor for the purposes of VOA’s functions. Any such disclosure would breach both.

I am sorry we are unable to fulfil your request but hope the explanations provided are helpful.

Links to connected documents:

ICO decision –

Reference:   IC-212134-G5G6 

Decision notices – ICO

FTT dismissal –

Reference:  EA-2023-0237

https://www.bailii.org/uk/cases/UKFTT/GRC