A financial institution notice (FIN) under paragraph 4A of Schedule 36 to Finance Act 2008 lets HMRC require a bank, building society or other financial institution to hand over information or documents about a named taxpayer, without the taxpayer’s agreement and without tribunal approval. An authorised HMRC officer must approve it and the request must not be onerous for the institution. The taxpayer normally receives a copy and a summary of HMRC’s reasons, but has no right of appeal against the notice itself.

What is a financial institution notice?

Paragraph 4A(1) of Schedule 36 allows an officer, by written notice, to require a financial institution to provide information or produce a document if two conditions are met:

  • Condition A: in the officer’s reasonable opinion, the information or document is of a kind that would not be onerous for the institution to provide.
  • Condition B: it is reasonably required to check the tax position of another person whose identity is known to the officer, or to collect that person’s tax debt.

The power was inserted by section 126 of Finance Act 2021. HMRC’s report to Parliament explains why: an OECD review recommended that the UK speed up its responses to overseas requests for tax information. The international standard is 180 days, and in 2018 the UK’s average was 12 months, largely because an ordinary third party information notice needs the taxpayer’s agreement or tribunal approval under paragraph 3. A FIN needs neither, and HMRC can use it for domestic compliance checks too. It sits alongside the other Schedule 36 powers described in our guide to Schedule 36 information notices.

Which institutions can receive one?

For this purpose a financial institution means a financial institution under the OECD Common Reporting Standard (CRS), other than one that qualifies only because it is a particular type of investment entity, plus any person who issues credit cards. HMRC’s guidance at CH23110 says this includes all banks and building societies, custodial institutions, depository institutions and specified insurance entities. A credit card issuer is the business that provides the card to the customer, not the payment network behind it such as Mastercard or Visa.

The 2024 to 2025 report notes that OECD amendments to the CRS definition, effective from 1 January 2026, bring specified electronic money products and central bank digital currencies into scope, and that HMRC expects this to widen the range of institutions receiving FINs.

What safeguards apply?

  • Authorised officer approval. A FIN can only be given by an authorised officer or with one’s agreement (paragraph 4A(5)). CH23120 says the authorised officer must be satisfied that, where appropriate, reasonable steps have been taken to get the information from the taxpayer first.
  • Taxpayer first. HMRC’s guidance at CH23105 is to try to obtain the material from the taxpayer, using a taxpayer notice if necessary. Where only statements for the taxpayer’s own account are needed, CH23120 says the taxpayer should normally be asked to obtain them, unless HMRC suspects they may be distorted.
  • Named taxpayer, copy and reasons. The notice must name the taxpayer (paragraph 4A(6)), and HMRC must give the taxpayer a copy of the notice and a summary of the reasons why the information is needed (paragraph 4A(7)). CH23140 says the summary must be meaningful and informative.
  • General Schedule 36 limits. A notice only covers documents in the institution’s possession or power (paragraph 18). It cannot require documents wholly more than six years old unless an authorised officer agrees (paragraph 20), cannot be given more than four years after a taxpayer’s death (paragraph 22), and does not cover privileged material (paragraph 23).
  • Annual scrutiny. HMRC must report to the House of Commons each year on its use of FINs, under section 126(6) of Finance Act 2021.

When can the taxpayer be kept in the dark?

HMRC can apply to the tribunal, without notice and with an authorised officer’s agreement, to disapply the requirements to name the taxpayer or to give the copy and summary of reasons. The tribunal must disapply the naming requirement if satisfied that the officer has reasonable grounds for believing that naming the taxpayer might seriously prejudice the assessment or collection of tax. It must disapply the copy and reasons requirement if satisfied that complying might prejudice the assessment or collection of tax (paragraph 4A(8) to (10)).

Where the copy requirement is disapplied, paragraph 51A allows the notice to forbid the institution from disclosing it to the taxpayer or anyone else, except for the purpose of complying. That requirement lasts 12 months and an authorised officer can extend it by further 12 month periods, but only with reasonable grounds for believing that not extending it might prejudice the assessment or collection of tax. An institution that breaches it is liable to a £1,000 penalty under paragraph 51B.

What rights does the taxpayer have?

The taxpayer’s main protection is advance knowledge: in the normal case the copy notice and summary of reasons are sent when the FIN is issued (CH23120). There is no appeal against a FIN. Part 5 of Schedule 36 gives appeal rights against taxpayer notices (paragraph 29), third party notices (paragraph 30) and identity unknown notices (paragraph 31), but none against a FIN, and HMRC’s factsheet CC/FS60 tells institutions plainly that they cannot appeal. An institution that thinks a request is onerous, or needs more time, is told to speak to the officer.

That leaves the taxpayer with practical rather than statutory routes:

  • raise concerns with the officer, for example where the request goes beyond what the summary of reasons supports or reaches material that falls within the Schedule 36 limits above;
  • complain about HMRC’s conduct, as covered in our page on HMRC complaints and the Adjudicator; and
  • in an exceptional case, seek judicial review. HMRC’s report records one judicial review application against a FIN in 2024 to 2025, which the High Court refused.

The more effective step is usually earlier. HMRC’s report says that in the majority of domestic cases it relied on a FIN because there was no response to, or no cooperation with, a taxpayer notice. Dealing properly with the taxpayer notice keeps control of what is provided and how it is explained.

What happens if the institution does not comply?

According to CC/FS60, the institution can be charged a £300 penalty, then daily penalties of up to £60 a day while the failure continues. Inaccurate information that it knows to be wrong can lead to a penalty of up to £3,000, and in the most serious cases the Upper Tribunal can impose a further penalty based on the tax put at risk. No penalty is charged if there is a reasonable excuse. The report notes that institutions can appeal against penalties. The rules are explained in our page on penalties for not complying with an information notice.

How often does HMRC use them?

Measure 2023 to 2024 2024 to 2025
Total FINs issued 1,143 1,307
Domestic FINs 918 1,134
FINs for international requests 225 173
FINs for debt collection 10 4
Applications rejected by authorised officers 114 208
Average response time to international requests 127 days 116 days

Source: HMRC’s fourth annual report on FINs, covering 1 April 2024 to 31 March 2025. HMRC compares the 1,307 FINs with 316,000 compliance checks in the same period. It attributes the rise in domestic use to non cooperation with taxpayer notices, taxpayers who no longer have access to their records, multiple accounts with different institutions, and more compliance officers.

How does this play out in a typical case?

Illustration only. A landlord under enquiry is asked for statements for a second bank account that received rent. He does not reply to the informal request or to the taxpayer notice that follows. The officer obtains an authorised officer’s approval and sends a FIN to the bank, naming the landlord and listing the account. The same day the landlord receives a copy and a letter summarising why HMRC needs the statements. He cannot appeal; the bank must comply.

The landlord now faces possible penalties for ignoring the taxpayer notice, and HMRC sees the raw statements before he has explained them. Providing the statements with an explanation at the taxpayer notice stage would have avoided both. Where HMRC wants information to collect a debt rather than check a return, CH23120 notes that a FIN can establish whether funds are available or find a current address, but that officers should use the separate direct recovery of debts information powers if recovery from the account is a possibility.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.