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HMRC internal manual

Compliance Handbook

The One to Many Approach: planning a one to many approach: who can help?

Different OTM approaches will involve different stakeholders. For every approach you will need to think widely to identify stakeholders and engage with them fully.

Identify key stakeholders

You must identify who your key stakeholders are across HMRC at the start of your thinking about an OTM approach. Engage with them early when you are developing your initial proposals. This will help them to understand and plan for any activity that you need them to contribute to, and to deliver this at the right time.

Bring together a group to think of all the stakeholders that you could involve. You will continue to add to this list as the work progresses, and one stakeholder brings in others. Others you will find no longer need to be involved.

Key stakeholders

You may have some specialists within your own Directorate who will be key stakeholders. There are some key stakeholders that must be involved in all OTM approaches. These are:

  • The Enforcement and Compliance (E&C) Strategy Unit 

You should consult with the E&C Strategy Unit first about your proposal for the OTM approach. It can offer input and advice which will come from a group whose members have a lot of experience in designing and delivering such activity. The E&C Stategy Unit maintains an overview of new compliance initiatives, as well as identifying E&C compliance priorities and resolving areas of cross-over or gaps in activity. Your business area should have representation on this Group. You should escalate your proposal through your management channel.

  • Knowledge, Analysis and Intelligence (KAI)

Consult with KAI to ensure you have a statistically valid sample for the proposed OTM approach KAI produce a variety of bespoke risk tools such as predictive scores, mismatches between data sets, knowledge based profiles or easy to understand management information. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

  • Campaigns Steering Group (CamSG)

The Campaigns Steering Group is the overall governance authority for OTM approaches within RIS, Individuals & Small Business Compliance (ISBC) and Wealthy & Mid-sized Business Compliance (WMBC). This forum comprises of representatives from across HMRC including operational, analytical, communication leads, KAI and E&C. It meets monthly and its function is to discuss, advise on and approve all planned OTM approaches in RIS, ISBC AND WMBC.

  • RIS Campaigns

RIS Campaigns is also an important source of advice for anyone in HMRC considering an OTM approach and can also advise on current and past campaigns.

  • Tax Administration Advice (TAA)

TAA is part of Central Policy and has technical responsibility for penalty legislation and the legal framework that addresses non-compliance. You should (This content has been withheld because of exemptions in the Freedom of Information Act 2000) ensure that your OTM letters do not give the customer an expectation that a compliance check has been opened or jeopardise their right to make an unprompted disclosure.

  • Compliance Operational Policy & Guidance Unit (COPGU)

COPGU will help to ensure that any compliance message you use is written in the right way so the customer knows what their rights and responsibilities are. This will reduce the risk of a legal challenge to your approach. COPGU will also advise on using HMRC’s standard approach to language and tone. (This content has been withheld because of exemptions in the Freedom of Information Act 2000) COPGU also has responsibility for this OTM guidance.

  • Central Customer Directorate

As part of Central Customer Directorate’s Behavioural & Customer Insight Team, the Behaviour Change Team has been established to support HMRC to:

  • improve delivery of key outcomes for HMRC and our customers
  • leverage behavioural insight and co-create changes to HMRC’s approach
  • build evidence using robust evaluation, including Randomised Controls Trials.

The Behaviour Change Team uses insights from behavioural science and research to create, test and apply enhancements to policy, processes, services and communications. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

  • CDIO Communications

CDIO Communications provides professional communications advice, support and services that will engage HMRC staff and enhance the Department’s reputation with stakeholders and the public. It is also important to remember there is legislation governing the Welsh language that you may need to follow.

 

When preparing your OTM approach you must factor in the time required to talk to all key stakeholders.