CH204020 - How to do a compliance check: notebooks for compliance checks: suitable notebooks

This page and chapter are under review as the relevant content is also published in the technical guidance chapters of the Compliance Handbook, within Compliance checks factsheets and in Compliance checks guidance. If you use particular pages regularly, please email hmrcmanualsteam@hmrc.gov.uk to let us know the specific content you find useful.


Compliance checks

Compliance officers may use electronic devises such as tablets or laptops for recording notes as long as you follow the detailed Digital notes instructions.

You must always use Microsoft Word to type your notes. At the end of the compliance check or meeting one must:

  • save the Word document as a PDF document
  • upload the PDF document to Caseflow, the appropriate case management system, or CAF within 24 hours of the end of the compliance check or meeting
  • delete both documents from your tablet or laptop.

If you need to add any further information about the compliance check or meeting, you must record this in a separate document, save it as a PDF and upload it to Caseflow, the appropriate case management system or CAF.

Paper notebooks used for recording compliance checks and notes of meeting can be either hard backed or soft backed, but they must be bound or stapled in the middle, so the pages are firmly fixed.

Notebooks with perforated pages are not suitable.

The pages do not need to be pre numbered. If the pages are not already numbered, you must number the pages on both sides when you start to use the notebook.

The size of the notebook you use will depend on the circumstances of your compliance check. There are different sizes of suitable notebooks available to order through the stationery green route.

Some ‘core HMRC’ products may not be available through the green route and so you will need to complete a business case to order them.

Departmental Notebook ENF 100A or Departmental Daybook ENF 102 must not be used unless you are carrying out a criminal investigation, as detailed below.

You must not use your tablet or laptop to make an audio or video recording of a compliance check or meeting with a customer

Criminal investigations

The ENF 100A or ENF 102 and the policies and procedures attached to their use must be kept for criminal investigations. The reason for this is that by using ENF 100A or ENF 102 in any circumstances where you are not carrying out a criminal investigation you are blurring the line between a criminal and civil investigation.

The use of these notebooks could be questioned during a Tribunal resulting in HMRC losing a case where we have proceeded down the civil route but appear to have followed criminal procedures.

It is only when HMRC decides to adopt a case for criminal investigation that any check becomes a criminal investigation. HMRC has policies and procedures in place to demonstrate this. To access the Suspected Fraud Identification Process please go to the CCG Guidance Hub, select your business area, then select 'Suspected Fraud Identification Process' from the Process Guides drop down menu. You'll find this product on the right-hand side of the screen.

When HMRC decides to follow the criminal route and subsequently conducts an interview, the person has certain rights that they do not have under a civil compliance check. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)