Guidance

How to request data from HMRC

Published 15 December 2025

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This publication is available at https://www.gov.uk/government/publications/requesting-hmrc-data-guidance-for-public-bodies/how-to-request-data-from-hmrc

Introduction

Who this guide is for

This guide is for colleagues in:

  • UK government departments
  • devolved governments
  • public bodies
  • local authorities

Use this guide when you need to request data from HMRC for policy development, operations or analytical purposes.

What you’ll learn

This guide explains:

  • what to consider before making a request
  • what data HMRC holds
  • HMRC’s legal requirements for sharing data
  • how to make a request
  • what to expect from the process

More information

You can find more information on…

1. What do I need to know before making a request for data?

Define your problem

Before contacting HMRC, clearly define:

  • the problem that you’re trying to solve
  • your objective
  • what’s preventing you from achieving this objective
  • the specific data that you need
  • whether the data will support one of your organisational functions

HMRC will ask you to explain what you’re trying to achieve and why HMRC data will help. Having clear answers will help HMRC respond quickly and effectively.

Check if you already have the data

Your organisation may already have the data you need. Check with:

  • colleagues in your policy area
  • your data sharing team
  • your Chief Data Office
  • your analytical team

Check if the data is publicly available

HMRC publishes large amounts of data on GOV.UK, including:

Check these sources before making a request.

Consider costs

There’s no charge for making a data sharing request or for HMRC’s data itself. However, there may be costs involved for:

  • extracting the data
  • providing the data
  • ongoing running costs
  • discovery or project work

Your organisation is responsible for funding any costs. HMRC can provide approximate costs once there is agreement in principle to share the data.

Plan your timing

Request data early in your project timeline, once you’ve:

  • defined your problem
  • explored all available options
  • determined that HMRC data is necessary

Don’t wait until just before:

  • project delivery deadlines
  • presenting options to a Minister

HMRC may not be able to meet tight deadlines, which could delay your work.

HMRC will be happy to have an initial high-level scoping discussion, prior to a formal request for data.

2. Does HMRC have the data I need?

What data HMRC holds

HMRC is one of the UK government’s largest data controllers. They collect and administer data on:

Direct taxes:

  • Income Tax
  • National Insurance contributions (NICs)
  • Corporation Tax
  • Capital Gains Tax
  • Inheritance Tax

Indirect taxes:

  • Value Added Tax (VAT)
  • Stamp Duty and other property taxes
  • environmental taxes (landfill tax, aggregates levy, air passenger duty)
  • behavioural taxes (tobacco duty, alcohol duty)

Other functions:

  • Child Benefit and Child Trust Funds
  • student loan recovery
  • statutory payments
  • National Minimum Wage enforcement
  • customs and excise duties
  • import and export data

How HMRC collects data

HMRC collects data to support its functions for the administration of the tax and customs system. This may differ from the requirements of other parts of government and mean that HMRC may either not have the data required or may not have it in a format that is suitable for your needs.

HMRC collects data through different methods with varying:

  • reporting requirements (some reporting is mandatory, some is optional)
  • time periods (Pay as you Earn (PAYE) income data is reported monthly, whereas Self Assessment income data can have long time lags)
  • collection frequencies (some data is collected in real time, some monthly, some annually)
  • sources (directly from the taxpayer, from an intermediary acting on their behalf, or from different third-party sources ranging from employers and online platforms to other parts of government and other administrative source

These factors may affect whether the data meets your needs.

Statutory duty of confidentiality

Under section 18 of the Commissioners of Revenue and Customs Act (CRCA) 2005, HMRC has a strict duty of confidentiality.

HMRC cannot share information unless they have lawful authority to do so, including to Other government departments and their agencies, local authorities, the police or any other public bodies.

When HMRC can share data

HMRC can share data:

  • for its own functions
  • with the person’s or organisation’s consent
  • where legislation provides a specific ‘gateway’
  • following a court order
  • for prosecutions
  • where disclosure is in the public interest
  • with devolved revenue authorities for devolved taxes

Data protection requirements

All government data is subject to rules and restrictions governing the circumstances under which it can be shared, alongside good public law principles.

HMRC’s statutory duty of confidentiality is in addition to any common law duties relating to confidentiality and is underpinned by a criminal offence for wrongful disclosure.

HMRC must comply with:

  • UK General Data Protection Regulations (GDPR)
  • Data Protection Act 2018
  • Human Rights Act 1998

Types of data

Most of HMRC’s data is personal data. This is information that can identify a living person, either directly or when combined with other information.

Information about companies or public authorities is not personal data; however, information about individuals acting as sole traders, employees, partners or directors may be personal data, where those people can be identified from the information.

Some personal data is designated as special category data (including race, religion, genetic and biometric data). This data is more sensitive and is only shared in limited circumstances.

It may be possible to anonymise personal data to ensure that it is no longer identifiable, depending on requirements.

Sharing data

Before processing and sharing personal data, HMRC must identify a lawful basis under the UK GDPR to do so, for example:

Most data sharing uses legal ‘gateways’ in separate legislation. There are 2 types:

  • mandatory disclosure: HMRC must or shall share the data
  • permissive disclosure: HMRC may choose to share the data

For permissive gateways, HMRC will consider whether disclosure is necessary and proportionate. Where HMRC refuses a request, HMRC will explain why.

Find the full list of gateways in the GOV.UK guidance.

Data management

All data shares need a signed memorandum of understanding (MOU) before data can be shared.

The MOU:

  • establishes the agreement between HMRC and your organisation
  • details each party’s responsibilities
  • outlines data security and handling standards

MOUs use HMRC’s standard wording but take time to agree and get sign-off.

For ongoing data shares, MOUs are reviewed annually using a Certificate of Review and Assurance.

For personal data requests, HMRC will need to complete a:

  • Data Protection Impact Assessment (DPIA): this assesses the impact of the request against data protection principles
  • Record of Processing Activity (RoPA): this documents the data management steps and ensure continued adherence to data protection principles

Once a data share is agreed, and before any data is shared, it is your responsibility to agree and secure sign off for the MOU alongside a DPIA or ROPA.

Once the data has been shared, how it is used depends on the legal basis; for example, data may be shared with another government department for fraud and error compliance purposes, under the appropriate legal gateway.

4. How to request data from HMRC

How to submit a request

Once you’ve determined you need HMRC data and identified a legal basis, submit your request to the Data Sharing Front Door team.

HMRC has a standard template for requests, which the Data Sharing Front Door team will provide. It covers these areas:

Question Information required
What data do you need? For example, aggregated/non-disclosive data, business data, personal data, data for research purposes, such as trade data
What do you need the data for? What is the problem that you are trying to solve? Have you considered alternative solutions? Have you checked whether your department already has the data or whether it’s already publicly available? Is your request critical to policy development, meeting a ministerial commitment, to improve service delivery etc? Is the data required to comply with your statutory functions, if so which ones?
What are your specific data requirements? Which specific data variables do you require? How much data is required? How frequently do you require the data? Can the data be anonymised or aggregated? Have you considered what is the minimum data required? Is the data necessary and proportionate for the use you are looking to put it to?
How would you prefer the data be shared? What is your preferred data sharing vehicle (for example an API, Secure Data Exchange Service) – noting that HMRC is restricted to specific data exchange methods and services, which may not be compatible with your organisation’s systems and processes.
Do you have plans to share the data further? Do you plan to onward share the data with another department? Will you be combining the data with other data sources? Will the data be leaving the UK? If you do plan to onward share, what is the legal basis for doing so?
What is the legal basis allowing HMRC to share this data with you? Does HMRC have a legal basis to share the data with you? Have you identified a suitable legal gateway to allow HMRC to share the data with you?
When do you need the data? What timescales are you working to? When would you ideally like to complete the data share?
What are the benefits of sharing this data? How will you measure the benefits to your department? Are there any benefits to HMRC of sharing this data? Are there any wider public benefits?

What happens next

The Front Door team will:

  1. review your request

  2. check the legal basis, data protection requirements, and data ownership

  3. pass approved requests to the Data Sharing Delivery Team

HMRC is restricted to specific data exchange methods and services which may not be compatible with your organisation’s systems and processes. The delivery team will work with you to consider options.

The process differs for:

  • low volume shares: often one-off requests that are processed more quickly
  • bulk shares: these may involve ongoing data feeds, IT builds, and higher costs

A pilot data share can be a useful starting point in addressing some of the reasons that shares; HMRC is happy to explore this as an option where appropriate.

Potential delays

Your request may be delayed if:

  • your requirements need refining
  • establishing a legal basis takes time
  • finding the data owner takes time
  • securing MOU sign-off takes time
  • identifying an appropriate sharing method takes time

Factor these potential delays into your project timescales.

Why requests might be refused

Your request might be refused if:

  • you’ve requested data that’s already publicly available or already shared with your organisation
  • HMRC doesn’t have the data that you need
  • there’s poor communication and engagement
  • your problem statement is too broad or imprecise
  • there’s no legal basis for sharing
  • you’re requesting large volumes of data as ‘nice to have’
  • you’ve made a complex request with an unreasonable deadline

What makes a good request

A good request includes:

  • a clear description of your problem and desired outcomes
  • evidence that you’ve explored other data sources
  • a detailed explanation of how the data will be used
  • specific variables, time periods, and frequency requirements
  • an appropriate legal basis
  • an indication of request priority
  • evidence the work meets your department’s priorities or statutory functions

Requesting analytical data

HMRC’s Cross-Government Analysis team can provide analysis and insights instead of raw data. They specialise in:

  • bespoke analysis of HMRC data for specific policy areas
  • Child Benefit, Tax-Free Childcare, and Tax Credits analysis
  • business analysis from Corporation Tax and VAT returns
  • employment, earnings, Income Tax, and National Insurance analysis

Contact the HMRC’s Cross-Government Analysis team at crossgovernmentanalysis@hmrc.gov.uk.

Get help

For initial discussions before making a formal request, contact the Data Sharing Front Door team.

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