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HMRC internal manual

Senior Accounting Officer Guidance

Reasonable excuse: when does a reasonable excuse end

Where a person has a reasonable excuse for a failure under the Senior Accounting Officer (SAO) provisions, they must remedy that failure without unreasonable delay after the excuse ends.

If they do this, we will treat the excuse as continuing until the date when they remedy the failure and will not therefore charge a penalty. If they do not do this, they will not have a reasonable excuse for the failure and therefore we will charge the penalty.

The Customer Compliance Manager (CCM), Mid-sized Business Customer Engagement Team (CET) or Caseworker must consider carefully the point at which a reasonable excuse ends and the actions the person took after that to remedy the failure. Each case must be dealt with on its own merits.

In terms of unreasonable delay, there is no statutory definition of ‘unreasonable’. Each case must be judged on its own merits in view of the person’s abilities and circumstances.


Janet was the SAO of a qualifying company. She was due to provide a certificate to HMRC by 30 June 2013. In late June she was unexpectedly hospitalised for an inflamed appendix. She was discharged from hospital in July 2013.

Janet had a genuine reason for not providing the certificate by 30 June 2013, but whether that was a reasonable excuse depends on how soon she provided the certificate after she was released from hospital.

If she provided the certificate within a couple of weeks of getting back to work, we would accept that she had a reasonable excuse for not providing the certificate by the required date. However, if she didn’t provide the certificate for several months then we would say that she didn’t have a reasonable excuse because she didn’t remedy the failure without unreasonable delay.

FA09/SCH55/PARA8 (2)(c)