Impact assessment

Economic Crime Levy - screening equality impact assessment

Published 8 June 2023

Project objectives

In the 2021 Budget, the government formally announced the introduction of a new Economic Crime Levy (ECL). This new legislation stipulates that entities regulated for anti-money laundering (AML) purposes whose level of UK Revenue exceeds £10.2 million will be required to pay the levy.

The levy will be collected by 3 statutory AML supervisors:

• HMRC
• the Financial Conduct Authority (FCA)
• the Gambling Commission (GC)

HMRC will be responsible for collecting this levy from the impacted AMLS entities they supervise, and the impacted entities supervised by one of the 22 Professional Body Supervisors (PBSs).

This will involve the delivery of a new digital service and customer support model to enable impacted entities to submit a ECL returns and pay any levy due on an annual basis.

This will be a 2 phased delivery:

Phase 1 will deliver a digital service that will provide, functionality for impacted entities to register with HMRC for ECL reporting, submit to HMRC a self-assessment of ECL liability and pay any ECL due.

This service will also allow an impacted entity to submit amendment details for their ECL registration or return information and request an ECL repayment.

Phase 2 will enhance the digital service delivered at Phase 1 to allow the customer to view previously submitted information, provide agent access (if User Research confirms this is required), make appeals and apply to de-register from ECL if they are no longer liable

This equality impact assessment (EQIA) has been completed to reflect the delivery of phase 1 only. This EQIA will be updated for phase 2 in due course.

Customer groups affected

Customer groups that will be affected are medium and large entities supervised by HMRC and PBSs for AML.

What customers needed to do

What customers needed to do as a result of the change

Entities will need to register with HMRC for ECL reporting, submit to HMRC a self-assessment of ECL liability and pay any ECL due.

How customers will access this service

Entities will access this service via GOV.UK/BTA. If an entity is not a UK Ltd company/UK LLP (unlikely due to criteria and customer base) the entity will have to register via a G Form.

When customers need to do this

Entities will need to submit their first ECL returns and pay any levy due by 30 September 2023.

Assessing the impact

Before the scheme started, we assessed the equality impacts on all the protected characteristic groups in line with the Equality Act and Public Sector Equality Duty and section 75 of the Northern Ireland Act:

• racial groups
• disabled and not disabled
• sex
• gender reassignment
• sexual orientation
• age
• religion or belief
• pregnancy and maternity
• marriage and civil partnership
• people with dependents and those without
• political opinion (for Northern Ireland only)

There is no evidence to suggest any specific impacts on those customers within any of the protected characteristic groups (listed above). The digital service will be fully accessible. Forms and guidance will be available in accessible formats if requested. Extra support will be provided as required through regular business channels.

The following equality impacts were identified:

People who use different languages (Including Welsh Language and British Sign Language)

Impact on customers

Some customers may wish to register for ECL, submit their ECL return and pay their ECL in Welsh.

Proposed mitigation

HMRC will ensure there are communication channels available for customers who are Welsh language speakers. Other mitigations include consideration of translation of guidance in Welsh.

Opportunities to promote equalities

We have considered opportunities to promote equalities and good relations between people in each of the protected characteristic groups and those outside of that group.

None have been identified.

A full equality impact assessment is not recommended.