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HMRC internal manual

Compliance Handbook

How to do a compliance check: authorised officer: classes of authorised officer: definition of a vulnerable person

A vulnerable person is someone in need of special care, support, or protection because of their age, disability or personal circumstances.  

Where you have concerns that a person may be vulnerable, you should consider the circumstances carefully and

  • explain the reasons for your decision when making any application for authorisation, see CH260500
  • identify any safeguards you will put in place to protect them, if your application is agreed by an authorised officer.  

A person under 18

There are already specific requirements in place when holding a meeting with a customer who is under the age of 18, see CH201350. You should take these into account when making any application to an authorised officer.

A person with a disability

You must not consider a person vulnerable solely on the basis that they have a disability. This would be discriminatory. Many people have disabilities that have no impact on their ability to manage their tax affairs.

Where a person has a disability you must make any reasonable adjustments they require, to ensure they are not disadvantaged when you carry out your compliance check. Further information on carrying out a compliance check on a person with a disability is at COG11360.

In circumstances where you think that despite making reasonable adjustments, the person will be disadvantaged by their disability you should consider whether they are a vulnerable person. For example, you may consider a person with certain learning difficulties to be vulnerable.

Where a person is unable to deal with their tax affairs see COG11360 and IDG30431.