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HMRC internal manual

Compliance Handbook

The One to Many Approach: planning a one to many approach: is one to many the right approach?

OTM approaches take time and cost HMRC resource. You must always consider whether an alternative approach is more appropriate. To decide whether an OTM approach is appropriate, you need to know the customer behaviours you want to target.

You will need to decide whether there are enough common characteristics within the customer group for an OTM approach to be effective. A suitable group of customers will not only display similar risks of non-compliance, they will also share reasons for their behaviour. So, for example, you would not use the same OTM approach on all customers who are late to file Self Assessment returns. Customers who file late because of difficult personal circumstances will respond differently to your approach to those who have deliberately chosen not to declare income.

You may want to consider developing different approaches and testing which of them work with a particular customer population.

The following questions will help you consider whether an OTM approach is appropriate:

  • How many customers are involved?
  • What is the cost to the department (either administrative or direct loss to the Exchequer)?
  • What precisely is the behaviour you wish these customers to improve?
  • Are they all behaving like this for the same reason?
  • What message, or change to existing communications, could influence this?
  • How will these customers react when they receive an OTM communication?
  • If you are asking the customers to review their return and make changes if needed, will HMRC follow up on this?
  • What will be the impact for operational colleagues of sudden increased contact to HMRC or changes to returns as a result of your OTM approach?


If you are in any doubt about any of these questions then an OTM approach may not be appropriate.

You should keep referring to these questions throughout your planning, as you gain more understanding of your customer population. You will need to be prepared to try something else, including no further action, if an OTM approach will not be effective.