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HMRC internal manual

Compliance Handbook

The One to Many Approach: approval: the process for gaining approval

The process in Enforcement and Compliance (E&C) for gaining approval for an OTM approach differs depending on your directorate. However, in general, each approach must consider the following:

  • Step 1 – Your proposal must be agreed within your Directorate. This will usually come from a Deputy Director. This is to ensure that it fits with the Directorate’s own strategy and does not clash with other activity elsewhere in the directorate.
  • Step 2 – You seek input to your proposal from the E&C Strategy Unit. This is a forum which aims to identify and share best practice for all new innovative activity in compliance. This includes trials of new approaches, OTM approaches, and other new activities aimed at promoting good compliance behaviours. If you send your proposal to the E&C Strategy Unit they will then discuss the planned activity with you. Your business area should have representation on this group.  You should escalate your proposal through your management channel.
  • Step 3 – Your proposal may need to be agreed with other stakeholders, depending on whether it affects their area of work. You can find a list of likely stakeholders at CH600280.


You should always check the approval stages operated by your own Directorate for a proposed OTM approach, and make sure you have obtained the right level of approval before starting your OTM approach, or if appropriate, taking your proposal to the Campaigns Steering Group (CamSG).

If you are in Risk & Intelligence Service (RIS), Individuals and Small Business Compliance (ISBC) or Wealthy and Mid-sized Business Compliance (WMBC), your proposal must also be agreed by CamSG.

The process for gaining the CamSG’s approval for an OTM approach has two gateways. All RIS, ISBC and WMBC approaches must pass through both gates before they can go ahead.

  • Gate 1 – The CamSG considers the approach early, at the proposal stage. The group will either agree to the proposal or suggest alternative approaches.


  • Gate 2 – The CamSG considers the final proposal before any customers are contacted.