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HMRC internal manual

VAT Registration

Variation of trader’s details: sensitive and non-sensitive changes

Sensitive variations are:

  • full name
  • trading name
  • PPOB address
  • all bank details
  • payment / repayment indicators
  • inclusion / withdrawal of partners
  • inclusion / withdrawal of group members.

Changes to a person’s sensitive details must be confirmed in writing by an authorised person (see VATREG33200). All sensitive changes advised by an assurance officer must be accompanied by a countersigned VAT 12 or supported by a suitable EF audit trail. For example, the change is recorded in officer’s visit report and the trader’s notification is countersigned by the officer and the officer’s manager prior to scanning.

This is required to ensure that the registration details are accurate and to guard against fraud.

Changes to the trade classification or stagger are not regarded as sensitive but you should reach agreement with the trader before you make any such changes. However, if the trader’s stagger is clearly disadvantageous to yield, we may impose the appropriate stagger or refuse the trader’s request to change. Written instruction from an assurance officer is sufficient to change these details. VATAC5000 provides guidance on how to deal with stagger manipulation by associated companies. (External readers can read this guidance at