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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and sanctions: non deliberate trading without approval

Trading without approval which is non-deliberate is neither

  • deliberate and concealed
  • deliberate but not concealed.

The non-deliberate penalty applies unless the behaviour is deliberate or the person has a reasonable excuse. See CH71500 for guidance on reasonable excuse. 

Example of Non-deliberate

Maria and Andy run a small cider-making business. They already have an excise registration to produce cider and they account for the excise duty and supply their product to three local retailers who they have supplied for a number of years. They do not realise they need to be approved for AWRS as they think their excise registration covers them for all their activities. They carry on trading until one of their customers asks them for their AWRS number. As soon as they realise they need to be approved, they apply immediately and do not make any further supplies until they receive their confirmation of approval.

Their behaviour was not deliberate, they have not concealed any of their activities and they sought to put the situation right as soon as they realised they needed to be approved.