Corporate report

Modernising HMRC’s approach to wealthy compliance

Published 28 October 2026

Foreword

HMRC is modernising the way it administers the tax system, making greater use of data and technology, improving digital services and investing in the expertise of its people.

This plan explains what that transformation means for the way we manage the wealthy taxpayer population.

Wealthy taxpayers make a significant contribution to the Exchequer and wider economy; the 1.3 million individuals in the population accounted for £160 billion in tax receipts in 2025 to 2026.

Their tax affairs can involve multiple taxes, businesses, investments, trusts and jurisdictions, making effective tax administration increasingly dependent on HMRC having a joined-up understanding of their circumstances.

Our aim is to make it easier for taxpayers to understand and meet their obligations, using better information to reduce unnecessary contact and identify potential problems earlier, whilst concentrating specialist compliance activity on the areas of greatest risk.

This is part of HMRC’s wider transformation; the actions in this plan will help us to provide better services whilst protecting the Exchequer and maintaining confidence that the tax system operates fairly.

Rt Hon James Murray MP
Financial Secretary to the Treasury and Paymaster General

Wealthy taxpayers

There are currently 1.3 million people in the wealthy taxpayer population, which HMRC defines as those with income over £200,000 or assets over £2 million in any of the last 3 years.

Wealthy individuals make a substantial contribution to the Exchequer, and most meet their tax obligations. However, the scale, complexity and international nature of some wealthy individuals’ affairs, and their access to sophisticated advice, can create greater scope for error, uncertainty and deliberate non-compliance.

Closing the tax gap is one of HMRC’s 5 strategic objectives. The wealthy tax gap for 2024 to 2025 was estimated at £3.6 billion, equivalent to 6% of the total tax gap.

As HMRC modernises, we have an opportunity to manage this diverse population differently. Better data, digital services and customer understanding will allow us to provide more effective support, identify potential problems earlier and focus specialist intervention where the evidence indicates greater risk. This builds on HMRC’s established approach of preventing non-compliance, promoting compliance and responding where risks remain.

Our approach to wealthy compliance forms part of the government’s vision for HMRC, set out in the Transformation Roadmap. Supported by the government’s investment in HMRC, alongside wider compliance measures, we will deliver on the government’s ambitions to increase tax revenues and reduce the tax gap.

In practice, our approach will:

• simplify and improve interactions with the tax system, including through better digital services, clearer guidance and greater certainty closer to transactions and key life events
• use richer data and stronger customer understanding to identify and address risks earlier, while reducing unnecessary contact for lower-risk customers
• deploy specialist expertise and HMRC’s full range of powers against deliberate and serious non-compliance
• work openly with agents, intermediaries, professional bodies, academics and other stakeholders to strengthen our evidence, test our thinking and shape future improvements

In May 2026, the National Audit Office published Collecting the right tax from wealthy individuals, report on examining HMRC’s compliance approach for wealthy individuals. We have continued to make progress since publication of that report, delivering our ambitions across 7 themes, each of which is explored in further detail below:

1. Improving our understanding of wealthy customers and enhancing our approach to customer segmentation.
2. Using better data, digital services and technology to prevent errors and identify risk earlier
3. Tailoring our compliance approaches to different customer circumstances and risk
4. Investing in our people and capability
5. Improving the customer experience and delivering better compliance outcomes
6. Working in partnership with customers, agents and external partners
7. Measuring progress and increasing transparency

Our commitments against each of these themes together constitute a multi-year programme of work to modernise HMRC’s approach to wealthy compliance. We will be transparent about progress against these commitments, including through progress updates to the Transformation Roadmap.

1. Improving our understanding of wealthy customers and enhancing our approach to customer segmentation

Commitment:

We will implement enhanced wealth identification approaches that bring together data from across HMRC systems and third parties to provide a more in-depth and holistic view of wealthy customers and their connected interests. This will improve our ability to distinguish between different types of customer and tailor our levels of support and intervention accordingly. We will regularly review and refresh this approach to consider new data and information as it becomes available.

A modern approach starts with understanding customers properly. Wealth alone does not tell us how someone interacts with the tax system, the complexity of their affairs or the support or intervention they may need.

Although the criteria have not changed, the number of individuals meeting HMRC’s definition of wealthy has grown from around 700,000 in 2021 to 2022 to 1.3 million in 2025 to 2026. This is a broad and varied population: customers differ in how their wealth is created and held, the complexity of their affairs, their behaviours and the commercial, economic and life events that shape their tax position. Income and asset thresholds remain useful for identifying customers who may have more complex affairs, but they do not provide a complete picture on their own.

We are therefore building a richer and more dynamic understanding of wealthy customers, including their connected entities and wider networks. By combining information about wealth, complexity, behaviour, structures, sectors, intermediaries and life events, we will identify the population more accurately, group customers with similar characteristics and distinguish between different levels of potential risk. Theme 3 explains how HMRC will translate that understanding into a proportionate compliance response.

Enhanced wealth identification approaches

Wealthy customers may hold income and assets through multiple businesses, trusts, partnerships and offshore structures, making it difficult to understand the full extent of their tax position from any single record. A more connected view will help HMRC identify the population more accurately and understand each customer’s connected interests and wider network. Theme 2 explains how priority data will be connected and analysed.

We will bring together customer, entity, third-party and open-source data and information to identify the wealthy population more accurately and reveal relationships that may not be apparent from individual records. This connected view will enhance HMRC’s understanding of how income, assets, businesses, trusts, partnerships and offshore structures relate to a customer and their wider network.

Enhanced identification and connected data will give HMRC a more rounded and reliable view of the wealthy population. We will use that view as the foundation for segmentation, risk assessment and tailoring of our intervention support and response. We will continue to recognise that complexity, a particular structure or participation in a sector does not in itself indicate non-compliance.

Enhancing understanding of the wealthy population

The wealthy customer population is large and contains many different types of customers, who interact with different parts of the tax system in different ways and present different levels of risk. For some of these customers, the scope to make errors or push boundaries is limited. For others, the level of interactions they have with the tax system or the behaviours they present means a need for greater oversight or interventions. Theme 3 describes how HMRC’s operational response will be tailored to different circumstances and risks.

We use customer insight and understanding so that we can better contextualise the different behaviours, structures, sectors and significant life events we see across the wealthy population. This includes thinking about the different archetypes, or personas, which make up the population. That insight and understanding of the range of customers in the population means we can better design services, guidance and compliance approaches.

The wealthy population and the risks within it will change as new information becomes available and customers’ affairs evolve. We refresh our population annually to determine what type of response is required to help wealthy customers pay the tax that is due and tackle non-compliance. 

For our wealthiest customers, in summer 2026, HMRC identified over 200 billionaires with a UK tax footprint using HMRC data, public information, data shared by third parties and other countries. We classify billionaires as individuals whose wealth HMRC estimates exceeds £1 billion and who have a UK tax footprint (which we define as being required to submit a UK Self-Assessment return, whether or not they are UK resident).

We will continue to review that population annually. We have allocated a Customer Compliance Manager (CCM) to every identified billionaire with a UK tax footprint and offered them a voluntary discussion. Theme 3 explains the CCM model and our response to this population.

2. Using better data, digital services and technology to prevent errors and identify risk earlier

Commitment:

We will connect priority customer, ownership and third-party data and responsibly use advanced analytics, automated triggers and artificial intelligence (AI) to identify emerging risks earlier and target compliance activity where it will have greatest impact. 

We will modernise digital tax administration for wealthy customers and their advisers and equip HMRC’s tax professionals with better-connected data, modern caseworking tools, secure digital channels and responsibly deployed AI, supporting better services and expert human judgement.

This will enable us to pre-populate more digital services each year and provide more targeted prompts to help wealthy customers and their advisers report accurately and correct errors earlier.

Wealthy customers’ tax affairs can involve several UK and international income sources, financial accounts, assets, entities and advisers. HMRC already receives substantial information through tax returns, Pay As You Earn (PAYE), connected entities, third parties, international exchange agreements and open sources, but its value depends on its quality, timeliness and the ability to connect it to the right customer and wider network.

Better information and modern technology can make tax administration simpler and more effective. They can help customers and their advisers understand their tax position and get their tax right, while giving HMRC earlier insight into potential risks and better tools to manage complex tax affairs. We will continue to adopt capabilities that improve customer outcomes, productivity and compliance, combining them with expert judgement and appropriate human oversight.

Pre-population and targeted prompts

Wealthy customers are more likely to have multiple UK and overseas income sources, financial accounts, assets and ownership interests. Where information is timely and accurately matched, we can make more of it visible through digital services so customers and advisers can see what HMRC already holds, understand what must be reported and address differences before they become more difficult to resolve.

Reforms announced at Spring Statement 2025 will improve the quality and usability of financial-account and card-sales data through consistent reporting requirements, stronger supplier checks and better matching to customer records. From April 2028, we will use this improved information to pre-populate more digital services, provide targeted prompts and identify wealthy customers who may need to register for Self-Assessment or report additional taxable income.

International exchange is equally important. UK leadership was key in setting standards for exchange of tax information, such as the Common Reporting Standard (CRS). The CRS was a significant step forward on global tax transparency, piercing through financial secrecy, and delivering visibility globally of the offshore financial accounts of taxpayers. HMRC now receives information from more than 100 jurisdictions on approximately 12 million offshore financial accounts each year. From 2027, we will use Crypto-Asset Reporting Framework data and enhanced Common Reporting Standard data to improve visibility of cryptoasset transactions, electronic-money products and indirect cryptoasset holdings; from 2030, participation in the Organisation for Economic Co-operation and Development (OECD) automatic exchange of real-estate information framework will improve our understanding of overseas property interests and income.

Case study 1: Targeted support through the non-domicile reforms

Using data and external engagement to help customers understand and meet new obligations.

176,000 customers identified as potentially affected

100,000+ targeted letters, emails and text messages

3,000+ webinar attendees

Action	Detail
Challenge	Reforms to the taxation of non-UK domiciled individuals took effect from April 2025. Customers, agents and employers needed timely, relevant information about how the new residence-based regime and related changes applied to them.
Action	HMRC used information it already held to identify those most likely to be affected. Support combined targeted communications, webinars, online guidance and engagement with agents, employers, representative bodies and the specialist non-domicile reform forum.
Impact	A data-led approach allowed support to be directed to the right audiences. It helped customers understand the changes, report accurately and address uncertainty earlier, while giving HMRC insight to improve future education and guidance.

We will also connect information from the Trust Registration Service and Register of Overseas Entities with customer, entity and third-party data. This will improve HMRC’s view of how wealthy customers hold and control assets, support clearer guidance and prompts where customers may have made an error, and enable earlier, targeted intervention where the evidence indicates greater risk. The trust and overseas ownership case study provides a fuller example of how this information is being used. 

Case study 2: Connecting trust and overseas ownership information

Bringing separate data together to understand complex ownership more quickly and accurately.

Trust Registration Service	Register of overseas entities	One view
Trusts, settlors, trustees, beneficiaries and assets.	Overseas entities with interests in UK property.	Customer, entity and ownership information connected.

Action	Detail
Challenge	Wealthy customers may hold assets through trusts, companies and overseas entities. Information about these arrangements has historically sat in different systems, making relationships harder to see and increasing the time needed to build a coherent view.
Action	HMRC improved access to information from the Trust Registration Service and the Register of Overseas Entities by integrating it into systems used by compliance officers and connecting it with customer and entity information.
Impact	A more connected view helps HMRC identify relationships and potential risks earlier, direct specialist resource more accurately and reduce repeated information gathering. It also supports more focused contact with customers and representatives because HMRC starts with a clearer understanding of the available information.

Connecting data


Information about wealthy customers, their assets and the entities and networks connected to them currently sits across different HMRC systems. We will connect priority customer, trust, company, partnership, overseas ownership and third-party data to create a more complete customer view, reveal relationships that may not be apparent from individual records and reduce the effort needed to gather and reconcile information.

We will apply improved analytics, automated triggers and responsibly deployed AI to this connected information, alongside intelligence and specialist insight. This will help us identify emerging and significant risks earlier, assess them more consistently and indicate where further support, enquiry or specialist intervention may be appropriate.

These capabilities will help compliance staff reach better-informed decisions, focus specialist resource on the most significant risks and reduce unnecessary contact for lower-risk customers. Theme 1 explains how the connected view supports identification and segmentation, while Theme 3 sets out how HMRC will translate the resulting assessment into a differentiated compliance response.

Modernising digital tax administration

HMRC is investing in the services, technology and infrastructure needed to modernise tax administration for wealthy customers and equip our tax professionals to manage increasingly complex affairs. Simpler and more joined-up customer journeys will be combined with better-integrated information and tools that help HMRC experts apply their judgement more efficiently and consistently.

Customer-facing administration will become more digital and timelier. Making Tax Digital for Income Tax will bring more wealthy landlords and sole traders into digital record-keeping and quarterly reporting between 2026 and 2028, reducing avoidable errors and giving customers and advisers a more current view of business and property income. We are also modernising Inheritance Tax administration towards an end-to-end digital service and will develop clearer digital journeys, using pre-population and targeted prompts where possible.

For HMRC colleagues, better-integrated customer records, modern caseworking tools and secure digital channels will improve visibility across taxes, entities, assets and advisers. This will reduce duplicated information gathering, support more coordinated engagement between HMRC teams and customers’ representatives and give tax professionals more time to apply specialist knowledge, test the evidence and resolve complex issues.

We will introduce AI-assisted tools to help compliance officers find relevant case information and guidance, identify patterns and connections, and consider potential risks and next steps. For example, these tools could automatically bring together information from multiple case records and documents to produce concise case summaries, answer questions about complex cases, and highlight relevant evidence. They could also help officers quickly locate and navigate HMRC guidance, policies and procedures through natural-language search. We will build on these capabilities towards 2030 to reduce administrative effort, improve consistency, and support earlier, more targeted compliance activity. AI will support, not replace, human decision-making: HMRC colleagues will remain responsible for compliance decisions and will apply their expertise to the facts, evidence and customer circumstances.

3. Tailoring our compliance approaches to different customer circumstances and risks

Commitment:

We will use deeper sector insight to develop and refine targeted approaches for different groups of wealthy customers, including clearer guidance, education and proportionate compliance interventions. In particular, we will assess the customer and compliance outcomes of our enhanced billionaire approach and consider any implications for our wider Customer Compliance Manager model.

HMRC has always tailored its compliance response to the circumstances of individual customers and the risks they present but modernising our approach will allow us to expand and improve on this tailoring. Improved identification and an ability to segment our population in different ways will allow us to do this more effectively and consistently, helping us build a richer understanding of different groups of wealthy customers and tailor our response accordingly.

Segmentation will help inform the appropriate nature, intensity and duration of our response. This allows us to act proportionately, while maintaining coordinated action where risks span different taxes, entities or connected individuals.

Our approach will continue to reflect the latest evidence and individual circumstances, recognising that risks can change over time. This means using guidance, digital services and targeted prompts where appropriate; focused intervention or coordinated CCM oversight where greater complexity or identified risks require it; and specialist, cross-tax and investigative capability for the most serious risks.

Sector insight, CCM oversight and the specialist programmes described below provide different but complementary ways to deliver that proportionate response.

Using sector insight


Wealthy customers’ affairs are often shaped by the sectors in which they operate, invest or generate their wealth. Commercial practices, remuneration models, ownership structures and the role of advisers can create distinctive tax issues in sectors including property and construction, financial services, professional sport, entertainment and cryptoassets. Participation in a particular sector does not itself indicate tax risk, but deeper sector knowledge helps HMRC better understand commercial practices.

We have strengthened this capability through external recruitment and engagement with industry, professional bodies and advisers. We will continue this engagement and will combine the resulting insight with HMRC data and operational experience to improve our understanding of commercial practices and the tax issues that can arise within particular sectors.

We will use this knowledge to identify where clearer guidance, targeted education or further compliance action is appropriate, assess the effectiveness of these interventions and use the evidence to refine our approach as sectors and business models evolve.

Case study 3: Using a sector-based approach to improve cryptoasset compliance

Combining education, specialist compliance activity and better data to support proportionate interventions.

180,000+ educational communications issued

800+  disclosures received through the Cryptoasset Disclosure Service

£188.4 million compliance yield delivered in 2025 to 2026 

Action	Detail
Challenge	Cryptoassets present distinct compliance challenges. The market is evolving rapidly, participation is widespread, and some customers may be unfamiliar with their tax obligations.
Action	HMRC established a dedicated Crypto Sector team and developed a tailored approach combining customer education, targeted communications, specialist compliance activity, improved use of data and intelligence, and close working across policy and operational teams, including our Fraud Investigation Service where appropriate.
Impact	The approach helps HMRC distinguish genuine errors from higher-risk or deliberate behaviour and tailor interventions accordingly. During 2025 to 2026, Wealthy and Mid Size Business Directorate’s cryptoasset compliance activity delivered over £188 million in compliance yield, including in excess of £168 million from activity designed to help customers get their tax affairs right and prevent non-compliance before it occurs. Insight from this work will support more effective use of existing information and expanded data available through the Cryptoasset Reporting Framework (CARF).

Customer Compliance Manager Model

Some wealthy customers have affairs spanning multiple taxes, entities, investments and jurisdictions, or involving significant transactions and changes in circumstances. As complexity increases, it can be harder for customers and HMRC to maintain a joined-up understanding of tax affairs, particularly where multiple specialists and areas of HMRC may need to be involved. Billionaires can present a particular example of this, with affairs often spanning multiple taxes, entities and jurisdictions and a greater need for early and coordinated engagement.

As set out above, every identified billionaire with a UK tax footprint has been allocated a CCM and offered a voluntary initial or pre-filing discussion. Early discussions will help build a shared understanding of the customer’s UK tax affairs and make subsequent engagement more focused and proportionate.

More broadly, where complexity or risk warrants it, CCM provides a clear point of contact, builds a joined-up understanding of the customer and their connected interests, and coordinates relevant HMRC teams and specialists to resolve issues earlier, reduce duplication and ensure that HMRC’s response is coherent and proportionate. CCMs are at the centre of HMRC’s understanding of the overall level of risk associated with a customer and in the minority of cases where deliberate non-compliance, avoidance or evasion is identified will support the deployment of HMRC’s full range of civil powers and criminal investigation capabilities

Around 8,000 wealthy customers are reviewed by CCMs each year to assess the level of engagement required. Of these, around 2,400 customers are allocated a CCM, supported by around 100 permanent CCMs and a wider network of tax, technical and compliance specialists. The nature and duration of oversight varies according to need, from ongoing engagement to targeted support around significant business, investment or transactional events. We will use improved insight to test whether CCM resource is directed where it adds most value and remains proportionate.

We will assess both the wider CCM approach and the specific experience of billionaires using customer surveys, compliance outcomes and operational insight. We will use the findings to improve how CCM resource is targeted, how oversight is delivered and how effectively the model supports earlier, more coordinated and proportionate intervention.

4. Investing in our people and capability

We will support the Transformation Roadmap’s wider ambition to give HMRC colleagues the skills, technology and specialist capability they need to deliver better outcomes.

Commitment:

We will bring in, retain, develop and share specialist expertise in areas including wealth management, family offices, offshore structures, trusts and Inheritance Tax, directing that expertise to the areas of greatest risk, including delivering on our commitment to increase by 400 the number of HMRC specialists focused on tackling offshore non-compliance by the wealthy by 2030 to bring in additional compliance yield from these risks

The Complex Cross-Tax and Offshore team and the High Risk Wealth Programme will bring together specialist expertise and powers needed to address risk across taxes, entities and connected individuals.

HMRC already brings together deep expertise in wealthy and offshore compliance, with specialist knowledge spanning tax, legal, commercial and international issues. This expertise is essential in dealing with customer affairs that can involve complex transactions, multiple taxes and entities, offshore arrangements, and specialist areas of law and commercial practice.

As customer affairs, business structures and compliance risks continue to evolve, we will further strengthen this capability. Better data, systems and technology will help our people work more effectively, but they cannot replace the technical expertise, professional judgement and confident leadership needed to resolve complex cases consistently.

We will build on existing strengths through increased capacity, targeted external recruitment, structured learning and career development, stronger knowledge-sharing, and effective management and assurance. Together, these measures will help HMRC deploy the right expertise to the areas of greatest risk and maintain the specialist capability needed to meet future challenges.

Coordinated response to the most complex risks

HMRC established the Complex Cross-Tax and Offshore (CCTO) team in April 2025 to strengthen its response to the most complex wealthy and offshore non-compliance. CCTO takes a holistic view of wealthy individuals, the entities and structures connected to them, and their wider impact across the tax system. It brings together more than 100 specialists from different tax regimes, working alongside externally recruited experts with experience of wealth planning and family offices. By combining cross-tax expertise, customer insight and specialist knowledge, CCTO can coordinate HMRC’s response where risks span personal and business taxes, multiple entities or offshore arrangements.

Where wealthy individuals, their connected entities or their intermediaries present the most serious and complex compliance risks, the High Risk Wealth Programme provides an intensive and coordinated response. It focuses on behaviours, structures or arrangements of concern, that may affect multiple taxes or involve those who design, promote or facilitate non-compliance. The programme brings together tax, legal, analytical, intelligence and investigative expertise through a multidisciplinary, project-managed approach, sustaining HMRC’s intervention until the identified risks have been effectively addressed.

In the most serious cases, including suspected fraud, we will draw on the full range of HMRC’s specialist capabilities and powers.

Impact of investment

Following the funding announced at Spring Statement 2025, we aim to recruit or redeploy an additional 400 specialists by 2030 to strengthen HMRC’s response to offshore non-compliance involving wealthy individuals, including risks involving the entities they control, and those who enable them. we have already recruited 244 people into roles across casework, intelligence, risk assessment, technical and operational functions.

This investment in people is being matched with wider investment in data, systems and technology. The additional specialists will help HMRC identify offshore risks earlier, investigate complex arrangements and pursue the tax due, while strengthening the intelligence, technical and analytical capability that underpins effective compliance activity.

We will complete the remaining recruitment and deployment of resources in line with evolving operational priorities. We will report how these specialists have been deployed across HMRC and use delivery and compliance evidence to assess the contribution they are making to tackling offshore non-compliance. These actions will contribute at least £500 million towards the commitment to raise £10 billion of additional tax revenues by 2029 to 2030.

Attracting, retaining, developing and sharing specialist expertise

Complex wealthy work requires specialist knowledge of areas including wealth management, family offices, offshore structures, trusts, Inheritance Tax and relevant commercial practice. Access to that expertise helps HMRC understand how arrangements operate, test the explanations and evidence provided and distinguish legitimate complexity from potential non-compliance.

We have undertaken targeted external recruitment of tax professionals with experience of wealthy tax affairs, offshore structures and wealth planning. We will continue to recruit externally where specialist knowledge can add the greatest value, informed by our evaluation of earlier recruitment and by emerging customer and compliance risks.

Recruitment is only part of building sustainable capability. We will retain and develop specialists, create routes for their knowledge to be shared through learning, guidance, communities of practice and case support, and deploy them according to changing risks. This will embed expertise across HMRC rather than leave it concentrated in individual roles or teams.

Strengthening capability

Through the Tax, Customs and Compliance Academy (TCCA), we are developing modular learning pathways for compliance professionals working on wealthy cases. These will combine strong core compliance skills with specialist learning in areas particularly relevant to wealthy customers, including Capital Gains Tax, trusts, Inheritance Tax, cryptoassets, offshore structures and commercial awareness.

We will complement this with targeted development for managers and stronger access to specialist expertise, case support and assurance. This will equip our people to understand complex wealthy affairs, critically assess explanations and evidence, and reach robust, consistent and proportionate decisions, while giving managers the skills and confidence to provide effective oversight and challenge.

Behavioural penalty decisions in complex wealthy cases require careful assessment of the facts and evidence. In April 2026, we introduced a mandatory referral process for complex penalty cases, established a specialist penalty network and delivered targeted training through TCCA. We will build on these measures by evaluating their effectiveness and using that evidence to strengthen our training, specialist support and assurance, helping ensure penalties are considered consistently, proportionately and on the evidence.

5. Delivering better compliance outcomes whilst improving the customer experience

This theme demonstrates how HMRC’s objectives of improving customer service and closing the tax gap, as set out in the Transformation Roadmap, can reinforce one another: better designed, more coordinated interventions should produce greater certainty for compliant customers and stronger action where risks remain.

Commitment:

We will improve the quality, timeliness and professionalism of our compliance work for wealthy customers, providing a more coordinated customer experience. At the same time, we will strengthen our use of intelligence, specialist capability, powers and sanctions to identify and tackle deliberate non-compliance and fraud among wealthy customers. We will also aim to secure prompt payment from those with the means to pay and take robust recovery action where customers do not engage, while responding proportionately to genuine financial difficulty.

Wealthy customers can have affairs spanning multiple taxes, entities, advisers and jurisdictions, so the quality and coordination of HMRC’s compliance work are particularly important. Well-managed interventions give compliant customers greater certainty and help HMRC resolve complex risks and secure the tax due efficiently. Where the evidence indicates deliberate behaviour, or a wealthy customer has the means to pay but leaves liabilities unpaid, earlier and stronger action will be taken to protect fairness for all customers and the Exchequer.

Improving quality, timeliness and professionalism

We will set clearer expectations at the outset of an intervention, explain the risks or issues being examined, request information in a focused and proportionate way, and keep customers and their representatives informed of progress. Where several HMRC teams or tax regimes are involved, we will coordinate activity to reduce duplication and provide a more joined-up customer experience.

We will strengthen case management and assurance so that enquiries progress at an appropriate pace, barriers are addressed and decisions are made consistently on the available evidence. Our aim is not simply to close cases more quickly, but to reach the right outcome efficiently and fairly, giving compliant customers certainty while ensuring risks are investigated fully and the tax legally due is secured.

We will assess improvement through a balanced set of relevant indicators, including enquiry duration, correspondence response times, complaints and wider customer and operational insight. We will use that evidence to identify where standards need to improve, while recognising that complex cases may legitimately take longer.

Strengthening our use of intelligence, specialist capability, powers and sanctions

For most wealthy customers, better information, earlier engagement and more effective services should mean fewer avoidable problems and more proportionate contact with HMRC. Where evidence shows deliberate non-compliance or serious harm, the same improvements in data, insight and coordination will enable HMRC to respond more effectively.

We will assess behaviour carefully and consistently, distinguishing error or uncertainty from careless, deliberate or fraudulent conduct. Intelligence, customer and third-party data, operational insight and specialist expertise will support that assessment and help direct the strongest consequences towards the individuals, structures and networks presenting the greatest harm. Theme 3 explains how HMRC will coordinate its operational response to the most complex cases.

The enhanced rewards scheme launched in 2025 provides an additional source of intelligence about serious non-compliance involving wealthy individuals, offshore structures, avoidance schemes and large businesses. We will assess information received through the scheme alongside intelligence from across HMRC and international partners, using it to identify risk and support targeted action where appropriate.

Where deliberate non-compliance or fraud is established, we will use the full range of proportionate civil and criminal responses available, including recovering the tax due, applying behavioural penalties, publishing details of deliberate defaulters where the statutory conditions are met, taking action against enablers and pursuing criminal investigations in the most serious cases. The number of penalties charged to wealthy individuals increased from 456 in 2023 to 2024 to 803 in 2025 to 2026. We will assess whether existing powers and sanctions are being used consistently and effectively and identify any operational or legislative barriers requiring further action.

By 2029 to 2030, we will increase annual charging decisions for the most harmful fraud by 20% from 2023 to 2024 levels, this will include wealthy individuals. Stronger intelligence, increased counter-fraud capability and closer coordination between wealthy compliance teams and HMRC’s specialist fraud functions will support this commitment. The objective is not simply to increase activity, but to ensure that the most serious deliberate behaviour is identified, investigated and met with visible and proportionate consequences.

Securing prompt payment

Where debt arises, we will act quickly to understand the customer’s circumstances and secure payment. We will improve the flow of information between compliance, customer management and debt teams so that emerging liabilities are considered sooner and HMRC’s activity is coordinated, particularly where an intervention is likely to result in a substantial liability or the customer has other outstanding debts.

We will use information held across HMRC to understand the customer’s wider financial position, including relevant assets, income, business interests and connected entities. This will help us distinguish customers experiencing genuine financial difficulty from those who have the means to pay but choose not to do so, allowing us to take action that reflects both their ability and willingness to pay.

We will expect wealthy customers with the means to pay to settle their liabilities promptly. Where a customer does not engage or chooses not to pay, we will take robust recovery action using the powers available and act to reduce the risk that assets are moved or dissipated before the debt can be recovered. Where a customer faces genuine financial difficulty or holds wealth that cannot readily be accessed or realised, we will consider the individual facts and work constructively with those who engage openly, while ensuring that any arrangement reflects their ability to pay, protects the Exchequer and secures the tax legally due as quickly as practicable.

6. Working in partnership with customers, agents and external partners

Commitment:

We will work openly with wealthy customers, advisers and representative bodies to improve understanding, support compliance and shape better services, including by supporting compliant agents and intermediaries while using strengthened powers and coordinated intelligence to act against those who enable non-compliance. We will also collaborate with academic, specialist and international partners to strengthen our evidence and understanding, using these insights to improve how we identify wealthy customers, assess emerging risks and design compliance approaches.

Wealthy customers’ affairs are shaped by professional advice, commercial practice, complex ownership arrangements and international activity. HMRC therefore needs insight beyond its own data and operational experience to understand how the tax system operates in practice and where services, guidance or compliance approaches may need to improve.

Different relationships serve different purposes. Engagement with customers and representative bodies can improve services and certainty; better visibility of agents and intermediaries can help us support good practice and address poor behaviour; and collaboration with academics, specialists and other tax administrations can strengthen our evidence and understanding of emerging and cross-border risks.

Working in the open

Direct engagement with wealthy customers, advisers and representative bodies can identify where HMRC guidance, services and processes create uncertainty or unnecessary difficulty. It can also help us understand how changes in commercial practice or customer behaviour affect compliance and where clearer communication would support customers to get their tax right.

HMRC already engages across a number of customer and adviser forums to get feedback on its operational approach, policy implementation and guidance. For issues relevant to the wealthy population, HMRC engages through the Wealthy External Forum, which brings together professional bodies and tax professionals twice a year to discuss issues affecting wealthy customers. In developing this plan, we have engaged with a broader range of customers, advisers, representative organisations and civil society groups and have reflected findings and recommendations from external scrutiny bodies, including the National Audit Office and Parliament’s Public Accounts Committee, using that insight to test and refine our approach. We will continue to seek opportunities to obtain a broader range of external insight to better inform and effectively tailor design of services, guidance and compliance approaches.

Agents and intermediaries

Professional advisers and intermediaries play an important role in helping wealthy customers understand and meet their obligations. We will support those who promote high standards of compliance, while improving our ability to distinguish good practice from poor conduct and identify those who facilitate or enable non-compliance.

From 18 May 2026, tax advisers interacting with HMRC on behalf of clients have been required to register and meet minimum standards. We will complete the phased implementation of mandatory agent registration and continue to improve and automate the new digital front door. Better visibility of advisers and their client populations will help HMRC recognise compliant agents, identify patterns of risk and target interventions more effectively.

Changes introduced in Finance Act 2026 give HMRC stronger powers to tackle tax advisers who intentionally facilitate non-compliance, known as sanctionable conduct. From 1 April 2026, these powers make investigations more effective and introduce tougher penalties linked to the tax revenue lost through an adviser’s actions. We will embed the framework into compliance activity and evaluate its effectiveness. Guidance on How HMRC deals with tax adviser sanctionable conduct is available on GOV.UK.

Dedicated agent-focused teams, including HMRC’s central Agent Compliance Team, will combine customer, agent and wider compliance insight and coordinate the use of HMRC’s powers. This will support a differentiated and proportionate response to adviser and enabler behaviour.

Collaboration with academic, specialist and international partners

We will establish regular dialogue with academic institutions and independent experts, identify relevant research and data sources and explore formal collaboration mechanisms, including memoranda of understanding and commissioned or jointly developed research where appropriate. Initial areas of focus will include estimating wealth, understanding how wealth is held and transferred, and identifying changes in the size and composition of the wealthy population.

Case study 4: Improving the evidence on wealth

Working with academic experts to strengthen how HMRC identifies and understands the wealthy population.

Evidence	Data	Options
Review research and existing methods.	Assess relevant sources and limitations.	Develop practical improvements.

Action	Detail
Challenge	Individuals are not required to report their total wealth to HMRC, and assets may be held through trusts, companies and other entities. Tax records alone therefore do not provide a complete picture of wealth, connected interests, complexity or risk.
Action	Following recommendations from the National Audit Office and Public Accounts Committee, HMRC is working with academic experts to review the evidence, assess available data sources and develop options for improving wealth estimation.
Impact	Independent expertise and challenge will help HMRC improve how it identifies and segments the wealthy population, understand connected entities and explain the strengths and limitations of its evidence more transparently. The findings will inform future identification, risk assessment and tax-gap methodology.

We will also work with other tax administrations through international forums, information exchange and direct bilateral relationships to understand internationally mobile wealthy individuals, complex cross-border arrangements and emerging offshore risks. Recent engagement with Norway, Singapore and Estonia, alongside comparisons with Australia, Canada, the Netherlands, New Zealand and the United States, has informed this plan and will provide a foundation for continued cooperation.

We will use this external insight alongside HMRC’s operational knowledge and administrative data to improve how we identify and understand wealthy customers, develop segmentation and risk models and design compliance approaches. It will also help us explain the strengths, limitations and uncertainty in our analysis more transparently. Theme 7 explains how external challenge will be applied specifically to the wealthy and offshore tax gap methodologies.

7. Measuring progress and increasing transparency

Commitment:

We will improve our confidence in the wealthy tax gap estimate and publish a standalone offshore tax gap estimate. Longer term, this should improve coverage and use of data and explain the relationship between the two measures, their uncertainty and the limitations in the available evidence.  We will continue to test and refine our wealthy and offshore tax gap methodologies with international tax administrations and the OECD Tax Gaps Community of Interest.

Reliable measurement is essential to understanding the scale and nature of non-compliance among wealthy customers, directing resources effectively and assessing whether the commitments in this plan are improving compliance outcomes.

Wealthy and offshore non-compliance is difficult to estimate because assets, income, ownership and behaviour can span multiple taxes, entities and jurisdictions, and no single source provides a complete picture. We will aim to improve the underlying data and methods, subject them to independent and international challenge and explain the uncertainty and limitations transparently.

Improving our confidence in the wealthy tax gap estimate

The wealthy tax gap for 2024 to 2025 was estimated at £3.6 billion, or 6% of the total tax gap. It currently captures liabilities arising from wealthy individuals’ personal taxes, including Self-Assessment, Inheritance Tax and Stamp Duty Land Tax. Measuring Tax Gaps 2026 gives the Self-Assessment component a high uncertainty rating, reflecting the complexity of wealthy tax affairs and limitations in the available data.

We will aim to improve the wealthy tax gap estimate by strengthening the evidence used for large partnerships. We are also exploring the wider tax risks associated with businesses controlled by wealthy individuals, including owner-managed businesses. This wider analysis will complement the wealthy tax gap estimate by helping us understand relevant liabilities that may be captured elsewhere in the tax gap.

In 2027, we will publish a standalone offshore tax gap estimate. This will build on HMRC’s 2024 publication of Undisclosed Foreign Income (UFI), which was published as official statistics in development and estimated under-declared tax relating to foreign income identified through Automatic Exchange of Information (AEOI) data. The UFI estimate represented only a narrow subset of offshore non-compliance and was not intended to be a comprehensive measure of the offshore tax gap.

Our longer-term ambition is therefore to develop a broader estimate that captures a wider range of offshore non-compliance affecting UK tax liabilities, including income, gains and assets held, arising or moved outside the UK. Publishing an offshore tax gap will improve HMRC’s understanding of the scale and nature of offshore non-compliance, support more targeted compliance activity, inform policy development and provide greater transparency in response to recommendations from external stakeholders.

The wealthy and offshore tax gaps will overlap because some offshore non-compliance relates to wealthy customers, but they measure different concepts. As the offshore estimate is developed, we will consider whether the element attributable to wealthy customers can be shown robustly and will explain clearly how the measures relate and where the evidence does not support a precise breakdown.

Testing and refining our wealthy and offshore tax gap methodologies

We have engaged external academics to challenge HMRC’s approach to measuring wealthy and offshore non-compliance. That work reinforced the importance of drawing on several evidence sources, being transparent about uncertainty and recognising the limitations of any individual methodology.

We will build on this through engagement with international tax administrations and the OECD Tax Gaps Community of Interest, alongside appropriate external expertise where this can add value. We will use their evidence and challenge to test assumptions, compare methodologies and identify relevant data and research, then publish material methodological changes.