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HMRC internal manual

Senior Accounting Officer Guidance

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HM Revenue & Customs
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Reasonable excuse: what is reasonable excuse - examples

This page gives some examples of what might constitute a reasonable excuse for a failure of the Senior Accounting Officer (SAO) provisions.

Please remember that these are hypothetical examples and are only intended to give Customer Relationship Managers (CRMs), the Mid-sized Business Customer Engagement Team (CET) or Caseworkers an idea of the factors they might need to consider. They are not model answers to a particular situation or the ‘correct’ way to deal with similar cases. Real cases will have many other factors to take into account and CRMs, the CET and Caseworkers need to consider each in the light of all the relevant facts. An excuse will not necessarily be accepted just because it seems to fit into one of these categories. It depends on the individual circumstances of each case.

If a company has not notified its SAO details within the time limit, see SAOG13400, CRMs, the CET or Caseworkers should bear in mind that a company knows who its SAO or SAOs were the day after the financial year has ended. If the company says it has a reasonable excuse for the late notification, CRMs, the CET or Caseworkers should explore why it didn’t notify the details much earlier in the filing period.

If an SAO has not provided a certificate within the time limit, see SAOG15700, CRMs, the CET or Caseworkers should bear in mind that the SAO may have to undertake some research after the end of the financial year to enable them to provide an accurate certificate. So unlike the company situation above the SAO may only have been in a position to provide the certificate towards the end of the filing period, CRMs, the CET or Caseworkers should check whether this was the case when considering the claim for reasonable excuse.

The person can appeal if we do not accept their excuse, see SAOG22000. See SAOG20800 for guidance about when a reasonable excuse ends.

Bereavement

We will normally accept that there is a reasonable excuse if the death of a close relative or domestic partner or SAO occurs towards the end of the period for filing their certificate(s).

This excuse is less likely to be reasonable where the company has failed to notify SAO details as there should normally be some person in the company other than the person who has suffered the bereavement who could take responsibility for notifying the SAO details.

Serious illness

We will normally accept that there is a reasonable excuse for not filing a certificate within the time limit, see SAOG15700, if a serious illness or accident of the SAO, their partner or a close relative occurs towards the end of the period for filing the certificate(s)

This is less likely to be the case when the company has failed to notify SAO details as there should normally be some person in the company other than the person who is affected by the serious illness or accident who could take responsibility for notifying the SAO details.

Unforeseen Events

We will normally accept that there is a reasonable excuse if the notification or certificate is lost or delayed in the post because of an unforeseen event disrupting the postal service. For example

  • fire or flood at the sorting office where the form would be held, or
  • prolonged industrial action.