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HMRC internal manual

Claimant Compliance Manual

Opening and Working Enquiries: Error & Fraud Analysis Programme enquiries

A small proportion of cases will be selected for full enquiry on an entirely random basis as part of the Error and Fraud Analysis Programme (EFAP). The selection will be carried out by Head Office from across the entire tax credits population. These cases are known as EFAP enquiries.

You should not operate an independent random selection programme, and only the centrally generated cases should be classified as “mandatory” for recording and monitoring purposes.

There are two main reasons for taking up EFAP enquiries

  • for deterrence, through creating an HMRC presence in all parts of the tax credits population, not just those perceived as higher risk. All customers should be aware that there is a chance we will make an enquiry into their entitlement for the year
  • to obtain a better understanding of the nature and extent of detectable non - compliance within different segments of the tax credits population. This will also help us refine our strategy and methods of identifying particular awards for enquiry.

Cases selected randomly should always be worked as full enquiries. You must not distinguish them from other enquiries in your dealings with customers or their representatives, even if they specifically ask you to do so. The CCRO will prepare a SIP which identifies all the significant risks, as for any other enquiry, and you should address all those risks in the normal way. This means obtaining all the information you need to decide whether the entitlement, and the amount of the award, were correct.

You cannot open an EFAP enquiry until the enquiry window is open - see CCM12030.