A complaint to HMRC is for poor service, such as delay, mistakes or poor behaviour, not for disagreeing with a tax decision. It goes through two internal tiers and then, if still unresolved, to the independent Adjudicator’s Office and finally the Parliamentary and Health Service Ombudsman through an MP. Where HMRC got things wrong it can make ex gratia redress payments covering reasonable costs, including professional fees, demonstrable financial loss and modest sums for worry and distress, set out in its Complaints and Remedy Guidance.
What can you complain to HMRC about?
HMRC’s complaints page says a complaint should only be made about the service received, giving delays in processing, poor communication or behaviour, and mistakes in handling a case as examples. A disagreement with a bill, a penalty or a decision about a relief needs an appeal or review instead, and HMRC warns that using the complaints route for these makes the response slower. See statutory review and the tax tribunal for that route.
Two practical points apply from the start. HMRC says you should keep paying tax while a complaint is dealt with, because stopping or delaying payment can lead to interest or penalties. And its staff guidance at CHG1110 confirms that an Adjudicator investigation does not stop HMRC taking administrative action, including pursuing a debt that is part of the dispute.
There is no strict deadline. CHG510 says HMRC asks people to complain as soon as possible but does not impose a time limit, and rejecting a complaint as too late should be the exception.
How do the complaint tiers work?
A complaint can be made online, by phone or by post. HMRC asks for the National Insurance number, UTR or VAT number, contact details, what happened and when, and how you would like the complaint resolved. An agent can complain online for a client but needs the client’s permission. If you need extra support because of a health condition or personal circumstances, say so when complaining.
- First tier. HMRC investigates what happened and what should have happened.
- Second tier. If you disagree with the outcome, a different person reviews the complaint and how the first tier handled it. The second tier decision is HMRC’s final word.
- Adjudicator’s Office. Free and independent of HMRC, available only once both tiers are complete.
- Parliamentary and Health Service Ombudsman. Reached by asking your MP to refer the complaint.
HMRC cannot investigate a complaint while the Adjudicator or the Ombudsman is investigating it. For the agent channels to try before complaining, such as the Agent Account Manager service, see escalating issues with HMRC as an agent.
What redress can HMRC pay?
Redress payments are ex gratia: CRG5025 says HMRC has no legal obligation to make them and they are not damages. The guiding principle is that the customer should not be out of pocket as a direct result of HMRC’s mistake, and should be no better off than if the mistake had not happened. HMRC states that these payments are not taxable, except where paid direct to an agent, when they are the agent’s trading income (CRG5100).
The main heads of redress are:
- Reasonable costs caused directly by the mistake or unreasonable delay, such as phone calls, postage and additional professional fees.
- Demonstrable financial loss, meaning loss supported by clear and verifiable evidence. HMRC will not pay for hypothetical, speculative or potential loss (CRG5025, CRG5125).
- Costs of complaining, where the complaint is upheld (CRG5350).
- Interest or bank charges actually lost or incurred because of the mistake. The redress payment itself does not carry interest (CRG5200).
- Payments for worry and distress and for poor complaint handling, covered below.
Some things are excluded. HMRC does not reimburse the normal costs of complying with tax obligations or of routine enquiries (CRG5100), and does not pay for a person’s own time unless there is clear evidence that earnings were permanently lost (CRG5175). Claims to top up repayment supplement or statutory interest simply because it seems inadequate should be refused (CRG5525). Payments over £5,000 need Director level authorisation (CRG5650).
Will HMRC refund an accountant’s fees?
It can, but only for additional work caused by its mistake or unreasonable delay. CRG5225 says HMRC does not pay for day to day costs an agent would charge anyway, and even an error put right at the first point of contact can be treated as day to day. Officers are told to ask whether the client usually uses that agent, whether the work was done at an appropriate level and usual rate, and whether the invoice has been paid. They will also question proportionality, whether the agent used the right HMRC contact point, and whether time on hold was billed.
Evidence is decisive. CRG5100 says HMRC normally needs receipts or paid invoices, and an invoice that does not separate normal work from extra work caused by the mistake may prompt a request for more detail, at the client’s own cost. CRG5450 adds that where fees are covered by insurance, such as fee protection insurance, there is no loss to reimburse.
What are worry and distress payments?
These acknowledge the impact of HMRC’s mistakes rather than any financial cost. CRG6075 says they are a token and usually range between £25 and £500, with most at the lower end, though they can fall outside that range in some cases. CRG6050 says they are made only to individuals, not companies, although a director of a one person company or an individual affected within a larger business is not ruled out. HMRC expects the impact to be raised early, not at the late stages of a complaint.
A separate payment, also usually £25 to £500, can be made for poor complaint handling, such as rudeness, lost letters, not admitting mistakes or unreasonable delay in dealing with the complaint (CRG6150). Time spent sorting things out is not paid by the hour, but CRG6100 says it can inform the size of a worry and distress payment.
What can the Adjudicator do?
The Adjudicator’s Office can investigate if you are the person affected or an authorised representative and both HMRC tiers are complete. It can normally accept a complaint up to 6 months after the second tier response, and later only in exceptional circumstances with reasons. It can look at whether policy and guidance were applied fairly and consistently, administrative errors including delays and poor or misleading advice, how discretion was used, and staff conduct. It cannot look at government policy, questions a court or tribunal can decide, ongoing investigations or enquiries, or formal decisions reached through alternative dispute resolution.
If it upholds a complaint it makes a recommendation to HMRC. Its 2026 annual report says it recommends redress in line with HMRC’s Complaints and Remedy Guidance, and that redress can include HMRC giving up recovery of a liability. In 2025 to 2026 it investigated 898 HMRC cases: 599 were not upheld, 57 fully upheld and 242 partially upheld. It also received 1,198 premature HMRC complaints that had not completed HMRC’s own process. Recommended HMRC redress totalled £227,912.45, of which £126,239.42 was liability given up and £17,005 was for worry and distress.
How might a claim for redress look?
Illustration only. HMRC wrongly allocates a client’s £8,000 Self Assessment payment to another taxpayer and issues penalty reminders for three months despite the agent’s letters. The client complains with the agent’s help. The first tier review upholds the complaint, cancels the penalties and asks for evidence of costs. The agent’s invoice separates normal compliance work from four hours spent tracing the payment and responding to reminders, and shows it was paid. HMRC reimburses those fees and the client’s postage, refuses a claim for the client’s own time, and offers £100 for worry and distress because the client raised the stress caused by the reminders when first complaining.
What mistakes weaken a complaint?
- Complaining about a decision that should have been appealed, and missing the appeal deadline.
- Stopping payments while the complaint runs, so interest builds up.
- Going to the Adjudicator before the second tier is complete.
- Claiming fees with a single undivided invoice, or before the invoice is paid.
- Raising worry and distress for the first time at tier two or with the Adjudicator.
- Missing the 6 month window after the second tier response.
The service standards HMRC is measured against appear in its Charter; see the HMRC Charter and your rights.
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Related Accountapedia entries
- Complaint or appeal: which route to take
- Should an accountant admit a mistake to a client
- Writing grounds of appeal for the tax tribunal
- Appealing a Self Assessment late filing penalty
- Client complaints procedures for accountants
Sources
- GOV.UK: Complain to hm revenue and customs
- GOV.UK: Manual page CHG510
- GOV.UK: Manual page CHG1110
- GOV.UK: Manual page CRG5025
- GOV.UK: Manual page CRG5100
- GOV.UK: Manual page CRG5125
- GOV.UK: Manual page CRG5175
- GOV.UK: Manual page CRG5200
- GOV.UK: Manual page CRG5225
- GOV.UK: Manual page CRG5350
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.
