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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: notes of meeting - when they are required

Notes of meeting form an important part of the compliance check process and should be used in conjunction with the Intervention Plan.

Notes of meeting are mandatory for any case where

  • factsheets CC/FS7a Penalties for inaccuracies in returns or documents and/or CC/FS19 Employer and contractor returns and ‘old’ penalty rules are issued and HRA advice provided along with factsheet CC/FS9 The Human Rights Act and penalties see COG906060 
  • there are ongoing issues at the end of the initial visit
  • the compliance check is as a result of a serious allegation
  • there is an allegation of inappropriate conduct by our staff
  • the employer/contractor answers “no” to the important question (COG905220).

If notes are required they should also be prepared for any further meetings.

Notes of meeting will not be required for cases where

  • factsheets CC/FS7a and/or CC/FS19 have not been issued as

    • inaccuracies are confined to the current year, or
    • on which no recovery will be made in a closed year, or
    • there are no in year penalties (CIS from 6 April 2007).

But if notes of meeting are not prepared details of verbal instructions given to the employer/contractor during the compliance check must be

  • recorded in the case papers
  • followed up in writing.

For details of how to prepare notes of meeting see COG905295.