SAOG19720 - What to do when there may have been a failure or inaccuracy: discussing reasonable excuse when a notification or certificate is late

When the Customer Compliance Manager (CCM) or Mid-sized Business Caseworker tells the relevant person - the company or Senior Accounting Officer (SAO) - about the potential penalty situation relating to a late notification or certificate, see SAOG19710, the person may claim that they had a reasonable excuse for the failure.

CCMs or Caseworkers can find guidance on reasonable excuse at SAOG20000.

If such a claim is made, the CCM or Caseworker must consider it and include it in their referral to the Penalties Consistency Panel, see SAOG19730.

At the same time, the customer may make representations that HMRC should exercise its discretion not to assess an SAO penalty, see SAOG18850.