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HMRC internal manual

MLR1 Penalties Guidance

HM Revenue & Customs
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Penalties guidance: identifying registration breaches: Regulation 27(4)

Registration breaches will be identified by both the Registration Team and Compliance Officers. Responsibility for deciding what penalty action is appropriate will depend on a combination of the specific regulations which has been breached and how the breach was identified. There are two specific types of registration breaches - Regulation 27(4) (below) and Regulations 26 and 33 - see MLR1PP5060.

  1. Regulation 27(4) Breaches of Regulation 27(4) - failure to inform us within 30 days about changes to details which were required at registration.

These breaches will normally be identified by

  • either the Registration Team when updating the register or processing the Reporting Changes form (template businesses use when advising of changes) or
  • our Compliance Team during a Compliance Visit or by our Central Intervention Team during a phone call.

Because the Registration Team are responsible for updating the register and have direct access to DTR, they will retain responsibility for issuing warning letters and penalties for Regulation 27(4).

If during a visit a Compliance Officer identifies changes to a business’s registration details which have not been notified to us, they should send a written report to the Registration Team together with any Reporting Changes form completed by the business. The amount of detail required in the report will depend on the specific circumstances but this should include details of any evidence gathered by the Compliance officer.

Regulation 27(4) breaches will in many cases be the result of error or neglect. We look at registration breaches again at MLR1PP9400