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HMRC internal manual

Senior Accounting Officer Guidance

What to do when there may have been a failure or inaccuracy: seeking authorisation of a Director or Assistant Director for a penalty

Authorisation by the Director in Large Business or Assistant Director in Mid-sized Business to assess a penalty must be obtained for

  • all main duty and certificate inaccuracy penalties, and
  • any sensitive or difficult notification or certification timing penalties.

Authorisation by the Director or Assistant Director to assess a penalty is not normally required for most notification and certification timing failures. However in some sensitive or difficult cases the Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker may receive approval from the Penalties Consistency Panel (the panel) to charge a penalty subject to final authorisation by a Director or Assistant Director See SAOG19730.

This submission must be made via the Chair of the Penalties Consistency Panel and include the CCM’s, CET’s or Caseworker’s first and second referrals to the panel and its responses.

A template for submissions to the Director or Deputy Director is available to all HMRC staff via the Large Business Operational Guidance Portal.

The Director/Assistant Director will notify the decision to the CCM, CET or Caseworker via the Chair of the panel.