Policy paper

Closing in on promoters of marketed tax avoidance schemes

Published 26 November 2025

Who is likely to be affected

Promoters of marketed tax avoidance schemes, and other professionals who market or enable the marketing of tax avoidance schemes, including within the tax, accounting and legal professions, are likely to be affected by these measures. Businesses that provide services to those promoters and other professionals will also be affected by some of the new measures. These companies would include providers of financial services such as banking and insurance and social media or technology companies.

General description of the measure

These measures will make a number of changes to the current legislation that targets those who promote or enable marketed tax avoidance.

Disclosure of tax avoidance schemes (DOTAS)

They will update the DOTAS civil penalty regime so that HMRC may directly issue DOTAS penalties instead of seeking tribunal approval.

DOTAS is an information disclosure regime that requires promoters of tax avoidance schemes to provide information about notifiable tax arrangements.

Disclosure of tax avoidance schemes for VAT and other indirect taxes (DASVOIT)

They will update the DASVOIT civil penalty regime so that HMRC may directly issue DASVOIT penalties instead of seeking tribunal approval.

DASVOIT is an information disclosure regime that requires promoters of tax avoidance schemes to provide information about notifiable indirect tax arrangements.

Universal stop regulations (USRs)

They will introduce universal stop regulations. The measure will introduce a:

• prohibition on promoting avoidance arrangements that have no realistic prospect of success
• power to allow HMRC commissioners to specify further arrangements in regulations which may not be promoted

This would apply to all promoters of marketed tax avoidance. A breach of this measure would attract a range of sanctions which would include publication, financial penalties and criminal prosecution.

Promoter action notices (PANs)

They will introduce promoter action notices. A PAN would require businesses to stop providing goods or services to promoters of tax avoidance where those goods or services are used in the promotion of avoidance and the promoter is in breach of a USR or stop notice.

PANs will primarily be issued to financial institutions, insurance companies, and social media companies. PANs will not restrict the provision of legal or auditing services or the provision of services that provide access to the internet.

Failure to comply with a PAN would attract a range of sanctions including publication, financial penalties and being reported to relevant representative bodies or regulators.

Anti-avoidance information notices (AAINs)

They will introduce anti-avoidance notices. An AAIN would enable HMRC to issue targeted notices requiring persons that HMRC reasonably suspects are connected to the promotion of a marketed tax avoidance scheme to provide relevant information including documents.

Sanctions for failure to comply would include a range of civil penalties and potentially criminal prosecution for more serious non-compliance. Additionally, a notice will be introduced that can be issued to financial institutions, with tribunal approval, to gain access to promoters’ or connected persons’ financial or banking data. Civil penalties would be applied for non-compliance but not criminal prosecution.

These changes would expand HMRC’s ability to assess compliance with obligations under HMRC powers and effectively investigate those who own and control promoter organisations.

Legal professionals facilitating avoidance

They will widen the scope of existing powers to ensure that HMRC can take targeted action against the small number of legal professionals that facilitate the promotion of avoidance schemes, by allowing the publication of legal professionals’ details under certain additional circumstances.

Policy objective

The actions of promoters of marketed tax avoidance facilitate non-compliance and contribute to the tax gap. These efforts to game the system generate no additional value for the economy and deprive vital public services of funding. The objective of the measure is to make a step change in efforts to close in on the small number of remaining promoters of tax avoidance. This would contribute to closing the tax gap attributable to marketed tax avoidance.

Background to the measure

The government announced at Autumn Budget 2024 that it would consult on these measures. A 12-week public consultation was launched at the Spring Statement 2025, and the consultation closed on 18 June 2025. A summary of responses to that consultation was published on 21 July 2025. The government included these measures in the draft Finance Bill 2025-26 and conducted a further technical consultation in the summer and autumn of 2025.

Detailed proposal

Operative date

The proposals will have effect at and after Royal Assent to Finance Bill 2025-26.

Current law

Disclosure of tax avoidance schemes

Related current law includes Part 7 of the Finance Act (FA) 2004 and section 98C of the Taxes Management Act 1970 (TMA).

Disclosure of tax avoidance schemes for VAT and other indirect taxes

Related current law includes section 66 of and Schedule 17 to F(No.2)A 2017, Indirect Taxes (Disclosure of Avoidance Schemes) Regulations 2017 (SI 2017/1215) and Indirect Taxes (Notifiable Arrangements) Regulations 2017 (SI 2017/1216).

Universal stop regulations

Universal stop regulation will be a new regime that complements but does not amend the existing stop notice regime. The legislation for stop notices is at sections 236A-K in Part 5 of FA 2014. Additional related legislation includes Part 10 of TMA and section 86 of FA 2022.

Promoter action notices

This will be a new power. The legislation is likely to interact with a number of existing legislative regimes including:

• part 7 of FA 2004 (DOTAS)
• part 5 of FA 2014 (Promoters of Tax Avoidance schemes)
• schedule 16 to F(No.2)A 2017 (Enablers of Tax Avoidance schemes)
• section 86 of FA 2022 (publication by HMRC of information about tax avoidance schemes)
• section 85 of FA 2022 (winding up petitions by an officer of HMRC)
• schedule 13 to FA 2024 (director disqualification)
• schedule 13 to FA 2022 (penalties for facilitating avoidance schemes involving non-resident promoters)
• section 87 of FA 2022 (freezing orders)

Anti-avoidance information notices

This will be a new power. The legislation is likely to interact with a number of existing legislative regimes including:

• part 7 of FA 2004 (DOTAS)
• part 5 of FA 2014 (Promoters of Tax Avoidance schemes)
• schedule 16 to F(No.2)A 2017 (Enablers of Tax Avoidance schemes)
• section 86 of FA 2022 (publication by HMRC of information about tax avoidance schemes)
• the legislation for Financial Institution Notices (FINs) in Part 1 of Schedule 36 to FA 2008

Legal Professionals

Related legislation includes:

• section 316C of FA 2004 (DOTAS)
• paragraph 36 of Schedule 17 to F(No.2)A 2017 (DASVOIT)
• section 86 of FA 2022 (publication of information about avoidance schemes)

Proposed revisions

Disclosure of tax avoidance schemes

Proposed changes include amendments to introduce changes to the penalty provisions to allow HMRC to issue penalties directly.

Disclosure of tax avoidance schemes for VAT and other indirect taxes

Proposed changes include amendments to introduce changes to the penalty provisions to allow HMRC to issue penalties directly.

Universal stop regulations

Proposed changes include new legislation setting out the blanket prohibition on schemes that have no realistic prospect of success as well as the purpose and process for issuing a new USR, including:

• requirements around introducing USRs in secondary legislation
• new financial penalties
• a new criminal offence

Promoter action notices

Proposed changes include:

• legislation describing how PANs would work
• a new certification process to allow HMRC to certify that a stop notice or USR has been breached prior to issuing a PAN
• a new publishing power
• new information sharing provisions
• new penalties
• a new power to report failures to appropriate representative bodies or regulators

A breach of a USR or Stop Notice would enable HMRC to issue a PAN. 

Anti-avoidance information notices

Proposed changes include:

• legislation setting out how the new AAINs would ensure HMRC can obtain information that would help it understand the operation of avoidance schemes at an early stage
• deploy, monitor and enforce compliance with existing and proposed anti-avoidance powers addressing promotion activities
• identify connected persons behind promoter group structures and take action against them

The legislation would also largely reflect the current financial institution notices (FIN) powers in Schedule 36 to FA 2008, with some modifications reflecting the purpose of allowing enquiry into promoter activities.

Legal professionals

Proposed changes include amendments to the various publishing sections in legislation, contained at:

• section 86 of FA 2022
• section 316C of FA 2004
• paragraph 36 of Schedule 17 to F(No.2)A 2017

This will be to effectively repeal current sections that restrict publication of the details of legal professionals. The legislation would include a declaration for legal professionals not involved in promoting schemes when legal professional privilege would prevent them from making representations to this effect.

The legislation would also introduce a penalty and new publishing power for legal professionals that make false representations.

Summary of impacts

Exchequer impact (£ million)

2025 to 2026	2026 to 2027	2027 to 2028	2028 to 2029	2029 to 2030	2030 to 2031
Negligible	Negligible	Negligible	Negligible	Negligible	Negligible

This measure is expected to have a negligible impact on the Exchequer

Macroeconomic impact

This measure is not expected to have any significant macroeconomic impacts. 

Impact on individuals, households and families

These measures are not expected to have an impact on individuals, households, or families. They are not expected to impact on family formation, stability and breakdown. 

These measures are expected overall to have no impact on individuals’ experience of dealing with HMRC.

Equalities impacts

These measures are not expected to have an impact on compliant individuals, therefore it is not anticipated that there will be disproportionate impacts on those in groups sharing protected characteristics. 

Administrative impact on business including civil society organisations

The overall business impacts of the proposed policy package are expected to be negligible. The measures are narrowly targeted at a small population of tax avoidance promoters, with limited reach into the wider market.

Most interventions are procedural or investigative in nature and do not impose new burdens on compliant businesses. Measures such as PANs and AAINs may involve third-party organisations (like banks, insurers, social media platforms) but the volumes are expected to be low and compliance is expected to be high. As such, the package is not expected to disrupt normal business operations.

These measures are not expected to impact civil society organisations.

These measures are expected overall to have no impact on businesses’ experience of dealing with HMRC.

Operational impact (£ million) (HMRC or other)

HMRC will need to update its IT systems to implement these policy changes. Work is ongoing to assess the changes required and estimated costs. They may also need to deploy more staff to administer and monitor the changes. Work is ongoing to design new processes and assess the associated resource requirements and costs.

Other impacts

A Data Protection Impact Assessment will be completed before the measures are implemented. Other potential impacts have been considered and none have been identified.

Monitoring and evaluation

These measures will be monitored through collection of HMRC operational data and feedback from stakeholders.

Further advice

If you have any questions, email the Counter-Avoidance Policy and Technical team at ca.consultation@hmrc.gov.uk.