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HMRC internal manual

Compliance Handbook

CH177280 - Sanctionable conduct by tax advisers: file access notice: penalties for failing to comply: time limits

A file access notice must state the date by which the documents must be provided. A person fails to comply with the file access notice if, without reasonable excuse, they do not provide all the required documents by the required date. Penalties can be charged if a person fails to comply with a file access notice.

However, we will not charge initial or daily penalties if we allow the person more time to comply with the file access notice, and they comply with the file access notice within that additional time.

FA12/SCH38/PARA24