HMRC compliance check factsheets explained

Q: Which factsheets explain HMRC's powers?

CC/FS2, information notices: sent when HMRC asks for, or formally requires, information and documents. CC/FS3, visits by agreement or advance notice: HMRC will usually give at least 7 days' notice of an agreed visit. CC/FS4, unannounced visits for inspections, and CC/FS5 where the tribunal has approved the inspection. CC/FS22, sending electronic records: used when HMRC wants copies of accounting software, spreadsheets or till data. HMRC says it will not ask you to convert paper records into electronic form. CC/FS23, third party information notices: used when HMRC asks someone else about you. CC/FS2 is the one to read closely. It lists what HMRC cannot require under an information notice, including documents you do not have and cannot get, material created to prepare for a tax appeal, documents only about personal welfare, privileged legal advice, and an auditor's or tax adviser's documents created as part of their job. It also says you cannot appeal against a notice that asks only for statutory records, or one the tribunal has approved. More detail is in Schedule 36 information notices.

CC/FS factsheets are short HMRC leaflets enclosed with compliance check letters to explain the check, the powers HMRC may use and the penalties that could follow. Every check comes with a general factsheet such as CC/FS1a, and HMRC adds others, such as CC/FS2 for information notices or CC/FS9 for human rights when penalties are in view, depending on what it is doing. They set out real rights and duties, but HMRC says they are guidance only and reflect its position at the time of writing.

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What are the CC/FS factsheets and why does HMRC enclose them?

HMRC publishes the series on GOV.UK as “HMRC compliance checks factsheets”. CC/FS1a opens by saying you have been asked to read it because HMRC has started a compliance check, and asks you to keep it because you may need it during the check. Each factsheet carries the same warning: it is for guidance only and reflects HMRC’s position when written. The law is in the statutes, such as Schedule 36 to the Finance Act 2008 for information powers and Schedule 24 to the Finance Act 2007 for inaccuracy penalties, not in the leaflets.

That still makes them useful. They are HMRC’s own statement of how it will run the check, and an officer who departs from them should be able to explain why. They also tell you which powers HMRC thinks it may need, because the factsheets enclosed track the stage the check has reached. The letter itself is covered in HMRC compliance check letters.

Which general factsheet will you receive?

Every check starts with one general factsheet. The collection groups six of them:

Factsheet	Who receives it
CC/FS1a	Most checks. It lists the taxes it covers, including Income Tax, Corporation Tax, Capital Gains Tax, VAT, PAYE, Construction Industry Scheme and Inheritance Tax.
CC/FS1b	Checks run by HMRC’s Campaigns and Projects teams
CC/FS1c	Large and complex businesses with a Customer Compliance Manager
CC/FS1d	Excise checks
CC/FS1f	Tax advantaged share schemes
CC/FS1g	Customs and international trade

CC/FS1c strikes a different tone from CC/FS1a. It says HMRC aims to discuss risks with large businesses first before considering formal powers, but may use them if the business prefers a formal approach, an assessment time limit is approaching, an issue cannot be resolved or a case is likely to go to the tribunal.

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Which factsheets explain HMRC’s powers?

CC/FS2, information notices: sent when HMRC asks for, or formally requires, information and documents.
CC/FS3, visits by agreement or advance notice: HMRC will usually give at least 7 days’ notice of an agreed visit.
CC/FS4, unannounced visits for inspections, and CC/FS5 where the tribunal has approved the inspection.
CC/FS22, sending electronic records: used when HMRC wants copies of accounting software, spreadsheets or till data. HMRC says it will not ask you to convert paper records into electronic form.
CC/FS23, third party information notices: used when HMRC asks someone else about you.

CC/FS2 is the one to read closely. It lists what HMRC cannot require under an information notice, including documents you do not have and cannot get, material created to prepare for a tax appeal, documents only about personal welfare, privileged legal advice, and an auditor’s or tax adviser’s documents created as part of their job. It also says you cannot appeal against a notice that asks only for statutory records, or one the tribunal has approved. More detail is in Schedule 36 information notices.

Which factsheets deal with penalties?

The penalties group is the largest. The ones most often enclosed in ordinary checks are:

CC/FS7a: penalties for careless or deliberate inaccuracies in returns and documents, prompted and unprompted disclosure, and the reductions for “telling, helping and giving”.
CC/FS7b: penalties for not telling HMRC within 30 days that an assessment is too low.
CC/FS9: your rights under the Human Rights Act when penalties are being considered.
CC/FS10: suspending penalties for careless inaccuracies (see suspended penalties).
CC/FS11: penalties for failing to tell HMRC in time that you have become liable to tax or need to register, for example for VAT.
CC/FS13 and CC/FS14: publishing details of deliberate defaulters, and the managing serious defaulters programme.

CC/FS21 explains alternative dispute resolution, which CC/FS1a says is available only for disputes in particular tax areas. See ADR for tax disputes. Other factsheets in the collection cover specialist regimes, such as offshore penalties, tax avoidance schemes and the general anti abuse rule.

What rights do the factsheets set out?

Across the general factsheets and CC/FS9, HMRC tells you that you have:

the right to be represented by anyone you choose (CC/FS1a);
a choice about whether to attend a meeting to discuss your affairs (CC/FS1a), although an information or inspection notice cannot be ignored;
the right, if you think the check should stop, to tell HMRC why and, if it disagrees, possibly to ask the tribunal to decide (CC/FS1a);
three options when you disagree with an appealable decision, which must be used within 30 days of the letter: send new information to the officer, ask for an HMRC review, or go to the tribunal (CC/FS1a);
when penalties are being considered, the right under Article 6 not to answer HMRC’s questions, which does not extend to information or documents that already exist and that HMRC can legally require (CC/FS9);
the right to have penalties dealt with without unreasonable delay, and to have tax and penalty appeals considered together (CC/FS9);
respect for your home and privacy under Article 8, with officers entering only the business parts of a home unless invited in or valuing property (CC/FS3 and CC/FS4).

The wider standards are in the HMRC Charter, which CC/FS1a refers to.

What duties do they set out?

You must take reasonable care to get things right, and that duty remains if an adviser prepares your returns (CC/FS1a).
You should keep filing returns and making payments during the check (CC/FS1a).
Failing to comply with an information notice can lead to a £300 penalty, then daily penalties of up to £60, and later a tax geared penalty that the tribunal must authorise (CC/FS2).
Carelessly or deliberately giving inaccurate information or documents can cost up to £3,000 for each inaccuracy (CC/FS2).
Concealing or destroying documents HMRC has asked for, or said it will ask for, can lead to a penalty, and where the notice was tribunal approved it is a criminal offence (CC/FS2 and CC/FS3).

How do the factsheets affect the size of any penalty?

CC/FS1a and CC/FS7a explain that penalty reductions depend on the quality of disclosure: telling HMRC what is wrong, helping it work out the figures, and giving access to records. Refusing a visit or holding back requested documents counts against you. CC/FS1a also says that if it has taken you a long time, for example 3 years or more, to tell HMRC about something wrong, HMRC usually limits the reduction to 10 percentage points above the minimum of the penalty range. How the reductions are calculated is set out in penalty reductions for disclosure.

How might this work in practice?

Illustration only. A sole trader receives an opening letter with CC/FS1a and CC/FS22 asking for her sales spreadsheet and bank statements. Six weeks later, after she has not replied, a second letter encloses a formal information notice and CC/FS2. After the figures are agreed, HMRC writes that it is considering an inaccuracy penalty and encloses CC/FS7a and CC/FS9. Reading the sequence tells her adviser how the check has escalated: CC/FS2 means a formal notice with penalties for non compliance, and CC/FS9 means she may decline to answer questions about the penalty, though she must still produce existing documents HMRC is entitled to.

What are the common mistakes?

Treating a factsheet as the law. Where the wording and the statute differ, the statute wins.
Confusing an informal request with an information notice. A request can be discussed; a notice must be complied with or appealed.
Reading CC/FS9 as a right to withhold existing records.
Assuming a contract settlement can cover everything. CC/FS1a says contract settlements cannot be used for VAT or VAT penalties.
Missing the 30 day window in CC/FS1a for responding to an appealable decision.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.