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HMRC internal manual

Compliance Operational Guidance

HM Revenue & Customs
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Supporting Guidance: business records checks: BRC officer’s notebook: overview

You must use an official Business Records Checks (BRCs) Officer’s Notebook for all your BRC work.

BRC Notebooks are the main record of information you obtain during your BRC and are used to record the work you have carried out at the visit.

You need to have access to your notes and both you and your colleagues will need to be able to understand them some time after they were made. See COG940650 for guidance on completing your BRC Notebook.

Notebooks may be called upon as evidence for a review, appeal or tribunal case. The completion and management assurance of notebooks must therefore be of a high standard.

It forms the basis of the visit summary report and must be capable of supporting any subsequent conclusions, recommendations and decisions. The Notebook forms a critical part of the audit trail and if any decisions you made are challenged, your records will be examined.

Notebooks must be used to record:

  • all discussions with the customer and/or their nominated representative
  • all business records identified, produced and inspected
  • which, if any, of HMRC’s educational products on record keeping have been used
  • which of the records seen are the statutory business records
  • the start and end of the period of the records provided for review.

You must record all checks applied to records you have seen, including:

  • details of the check carried out and the period to which the check relates
  • details of specific documents inspected (including numbers or other references)
  • all risks identified
  • visit outcome
  • all verbal decisions given and the nature of any inadequacies identified
  • exceptionally, all further records and information requested at the end of the visit
  • details of any other issues discussed with the customer including anything said by the customer that you use to support your decision on the adequacy of the statutory records or that relates to any record keeping penalty position
  • any reasonable adjustments made under the Equality Act 2010.

All BRC Notebooks must be maintained properly and kept securely at all times. Notebooks may be called upon as evidence for review, appeal or tribunal cases at any stage in the future.

In addition they

  • may be used as evidence in tribunal proceedings
  • ensure that information is not lost as memory of the visit fades
  • can be used for management checks.

Therefore you or your colleagues must be able to access your notes and understand them some time after they were made. See COG940650 for guidance on completing your BRC Notebook.