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HMRC internal manual

Special Measures

From:
HM Revenue & Customs
Published:
2 October 2026
Updated:
2 October 2026 - See all updates

SM01000 - Special Measures: Introduction

Legislative reference

This manual is a guide to Special Measures as provided for by Schedule 19, Part 3 of the Finance Act 2016 (2016 c.24).

Intention of guidance

This manual is to support HMRC staff and customers understand how Special Measures work in practice.

Guidance will be updated if HMRC’s interpretation of the law changes.

Overview

HMRC takes a ‘co-operative compliance’ approach to managing risk with large businesses, in line with the principles established by the Organisation for Economic Co-operation and Development (OECD). The principles are made up of seven pillars, covering areas such as impartiality, openness and transparency.

To facilitate the co-operative compliance approach, Special Measures is a compliance regime designed for a small number of large businesses that persistently fail to engage with HMRC in a collaborative and transparent way. The Special Measures regime is a structured set of rules and obligations imposed by HMRC to ensure businesses meet their tax responsibilities and improve their approach to compliance. Its purpose is to support improved compliance and fairness in the tax system. The Special Measures regime compliments other compliance initiatives such as the Business Risk Review+ (BRR+) and the High Risk Corporates Programme (HRCP).

Special measures apply only where unco-operative behaviours persist and the large business poses a significant risk to the Exchequer. Large businesses placed under Special Measures face sanctions, including potential public naming by HMRC Commissioners, if further non-compliant behaviours occur.

Entry into Special Measures:

  • HMRC assesses risk and behavioural criteria, such as how a business cooperates with HMRC, to determine eligibility
  • before entry, HMRC issues a formal warning and allows a 12-month improvement period for the business to address concerns
  • if behaviour improves, Special Measures will not apply; if it does not, HMRC will confirm entry into the regime

Once applied, Special Measures last a minimum of 2 years. After this period, HMRC will conduct an exit review to decide whether the business should leave or remain in Special Measures.