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HMRC internal manual

Senior Accounting Officer Guidance

What to do when there may have been a failure or inaccuracy: referral to the Penalties Consistency Panel when a notification or certificate is late

Once the Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker has gathered all the information relevant to a penalty decision, they must make a referral to the Penalties Consistency Panel (‘the panel’).

In this referral the CCM, CET or Caseworker must present all the relevant information, including a clear record of

  • any technical specialist advice sought and provided, and
  • discussions with the company / Senior Accounting Officer (SAO).

They must also make a recommendation on whether a penalty should be charged or not.

A template for submissions to the panel is available to all HMRC staff via the Large Business Operational Guidance Portal

The panel will then decide whether to approve penalty action, though in sensitive or difficult cases it may instruct the CCM, CET or Caseworker to refer to the Director in Large Business or Assistant Director in Mid-sized Business for authorisation, see SAOG19800.