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HMRC internal manual

Compliance Operational Guidance

HM Revenue & Customs
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Supporting Guidance: employer compliance: guidance by subject: penalties: CIS until 05-04-07 - submission of inaccurate or incomplete CIS25 vouchers

COG909570 explains the types of vouchers used under CIS until 05-04-07 and the action to be taken by a contractor / subcontractor.

ICTA1988/S566(2C) provides for

  • a penalty not exceeding £3000

where a contractor has

  • failed to properly inspect a registration card, and has as a result
  • submitted inaccurate or incomplete CIS 25 vouchers and they are
  • inaccurate or incomplete in any material respect.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

If the contractor

  • inspected a valid registration card, or
  • a document that he had reasonable grounds to believe was a valid registration card


  • took reasonable steps to make sure that the vouchers were correct

a penalty will not be sought in accordance with S566(2D).

Whenever you identify that a contractor has submitted inaccurate or incomplete CIS25 vouchers you must

  • establish the extent of the errors/omissions
  • explore the reasons for the errors/omissions and
  • consider whether a penalty is appropriate.

Before seeking this penalty you can

  • contact TAA Technical for advice - see COG904770.

Where the contractor’s actions have resulted in an incorrect CIS 36 being submitted you should

  • consider penalties under S98A4 TMA 1970 COG914070.