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HMRC internal manual

Compliance Operational Guidance

HM Revenue & Customs
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Supporting Guidance: employer compliance: guidance by subject: commencing the compliance check: importance of the talkthrough and testing the systems

The talkthrough is a vital part of the compliance check as it is the opportunity to gain an understanding of the employer’s/contractor’s business and the systems in place to enable the business to function properly, and enable the employer/contractor to meet his statutory obligations.

It also gives an employer/contractor the opportunity to disclose any problems at an early stage in the check.

It is important that the talkthrough is conducted with:

  • the owner, partner, director or company secretary because they will have the knowledge of the business, and if applicable
  • the appropriate person or persons with the knowledge of the systems in operation.

At the start of the talkthrough you must give the employer/contractor the opportunity to disclose by:

  • giving the employer/contractor the opportunity to tell you about any matters that have not already been covered and
  • asking the important question ‘have all payments to employees and directors been taxed, NIC accounted for and the payments entered in the pay records?’ (COG905220).

During the talkthrough you should obtain a full description of:

  • the business (what it does and how long it has been operating, the number of locations, the size and nature of the workforce for example), and
  • each system that the employer/contractor operates.

You must remember that:

  • there may be sub systems within systems, and
  • a system still exists even if it has only been operated once, for example the transfer of an asset.

You must record full details of each system on the system tested. It is important to record exactly what records were seen during the course of a Compliance Check, what tests were applied and what was discovered.

For Caseflow cases you need to update Case information in

  • Records Description - record exactly what records were seen during the compliance check and note the risk these relate to.
  • In Risk notes for each risk complete the following boxes:

    • Activity to test - Record a full description of each system and any sub systems in operation, include the controls in place and any authorisation procedure used.
    • Outcome - Record full details of potential risks.
    • Behaviour - Record the behaviour leading to the potential inaccuracy.

For ECS cases the Intervention plan and systems template is completed to record the details as above. This is available via SEES together with help on its completion.