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HMRC internal manual

Compliance Handbook

Dishonest tax agents: publishing details of tax agent dishonest conduct: time limits for publishing details

There are two time limits for publishing the details of dishonest conduct.

The two time limits are:

  1. the time limit within which we can first publish a tax agent’s details, and
  2. the time limit within which we have to remove a tax agent’s details from publication.



  1. Time limit to start publication

We must not publish a tax agent’s details before the day on which the penalty becomes ‘final’, or the latest day on which the penalty becomes ‘final’, and the details cannot be published for the first time after 12 months from the date on which the penalty became ‘final’.

A penalty becomes ‘final’ on

  • the day after the end of the appeal period if the person does not make an appeal, or
  • the date when an appeal is finally determined.
  1. Time limit to stop publication

The details can only continue to be published by HMRC for one year from the date it first publishes them.


FA09/S94 (7)
FA09/S94 (8)
FA09/S94 (9)