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HMRC internal manual

Tax Compliance Risk Management

The Business Risk Review (BRR): Revisiting the BRR: Moderation of BRR Status Reviews

Internal moderation within the LB Region should be carried out before the Risk status is shared with the customer for:

  • all reviews where a change of status is proposed (either to or from LR),


  • a centrally selected sample of all other BRR reviews where the existing status is confirmed.

The customers in the sample will be notified each year to the Deputy Director.

The moderation should be conducted by the CRM’s line manager and at least one other CRM from the LB Region and should include confirming the existence of the robust audit trail detailed at TCRM3380.

This could be done in a variety of ways: at a specific meeting about that case, as one item on the agenda of a meeting involving a number of CRMs or (if necessary) by email without a face to face meeting.

Additionally where the BRR status of a customer changes either from Low Risk to not Low Risk, or from not Low Risk to Low Risk the move should be agreed by the Deputy Director, or their nominated Assistant Director.