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HMRC internal manual

Compliance Handbook

CH177350 - Sanctionable conduct by tax advisers: file access notice: penalties for inaccuracies: Overview

A person is liable to a penalty of up to £3,000 if, in response to a file access notice, the person provides a document that contains an inaccuracy.

However, the person is only liable to a penalty if:

    • the inaccuracy is deliberate or due to a failure by the person to take reasonable care,
    • the person knows of the inaccuracy at the time the document is provided but does not inform HMRC at that time, or
    • the inaccuracy was not careless or deliberate, but the person discovers the inaccuracy sometime later and fails to take reasonable steps to inform HMRC.

The maximum penalty is £3,000 but we would only consider that amount for very serious cases of deliberate inaccuracy. Inaccuracies assessed as careless should typically attract a lesser penalty than inaccuracies assessed as deliberate.

Where a document contains more than one inaccuracy, a penalty is payable for each inaccuracy.

We will not assess a penalty for giving us an inaccurate document if the person

    • tells us about the inaccuracy at the time they give us the document,
    • takes reasonable steps to tell us about the inaccuracy if they later discover it, (before HMRC have asked about the inaccuracy).

FA12/SCH38/PARA 25A