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HMRC internal manual

Compliance Handbook

How to do a compliance check: starting a compliance check: openness and early dialogue

Local Compliance has committed to considering and applying openness and early dialogue (OED) principles when carrying out all compliance work. Caseworkers in other business areas may also wish to apply these principles as best practice

Customer research has demonstrated that by explaining

  • why you are undertaking a compliance check
  • what you need in order to complete a compliance check
  • why you require additional information or documentation

helps customers understand what we need them to do and reduces their concerns. It also helps reduce the time taken to resolve a compliance check.

OED does not override the use of formal powers to request information and documents, or a person’s legal rights. There may also be occasions where OED will not be appropriate.


At the start of your compliance check you must tell the person the risk or reason for your check. It may be that the person can explain and offer evidence to satisfy the risk identified.

When requesting documents or further information you must provide the person with an explanation of why you need these. Explaining why you require certain information will

  • help the person to provide it
  • prevent requests for unnecessary records.

Setting out clear expectations of how you intend to carry out your check and keeping the person informed of any emerging risks will help develop a collaborative relationship. 

There will be situations where you will not be able to share some or all the risks identified. If this applies to your compliance check you should explain

  • that you have the right to check whether the return is accurate and complete, and
  • that you do not have to offer OED.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Early dialogue

You must try and develop a rapport with the person as early as possible at the start of your compliance check. Early dialogue is about building an open and collaborative relationship and this approach will help to bring your compliance check to a timely and agreed conclusion.

You must encourage the person, or their agent, to talk as this will help both sides gain a better understanding of what you have asked for and why you want it. You must also try to agree a timescale for providing any requested documents or information.

You may decide to telephone a person, or their agent, to discuss or explain why you require certain documents or information or agree time frames. In simpler cases you may be able to agree an error or omission over the telephone.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Early dialogue does not override the use of formal powers.

Disclosure during a telephone call

Early dialogue encourages an increased use of the telephone and this in turn increases the opportunity for a person to make a disclosure of inaccuracies, wrongdoing or failures to notify.

If a disclosure is made during a telephone call you must follow the guidance at CH300950.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)