Should you meet HMRC during an enquiry

You do not have to attend a meeting with HMRC during an enquiry; HMRC’s own Enquiry Manual says officers have no power to compel a taxpayer or accountant to attend. But the enquiry continues either way, and HMRC can use formal information notices instead. A well prepared meeting, with your adviser present, can shorten an enquiry, while an unprepared one can widen it.

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Do you have to attend a meeting with HMRC?

No. EM1825 states plainly that HMRC does not have a power to compel a taxpayer or accountant to attend a face to face meeting. Officers are told to explain the advantages of meeting rather than insist, and to consider whether a telephone or video call would achieve the same result. They are also told to make clear that HMRC is entitled to enquire into the return and will pursue the enquiry even without cooperation.

Refusing a meeting is therefore not a penalty offence in itself, but it shifts the enquiry onto correspondence and, where documents or explanations are not forthcoming, onto formal requests under Schedule 36 (see Schedule 36 information notices). Unlike a meeting, a valid notice must be complied with. The decision should be made on the facts of the case, with your adviser.

Why does HMRC ask for a meeting?

EM1822 lists what officers hope to achieve. Early in an enquiry a meeting helps establish how the business runs, what records are kept and how transactions have been treated. It can also cover the owner’s or directors’ private financial affairs, explain the risks HMRC has identified and give the taxpayer the chance to disclose any errors. Later on, meetings are used to quantify and agree any additional liability, discuss behaviour for penalty purposes, agree payments on account and agree how the enquiry will be settled. EM1822 also says not every enquiry needs a meeting and that face to face meetings can be expensive and inconvenient for the taxpayer.

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What are the advantages and risks of agreeing?

A meeting lets you explain the business in context, correct misunderstandings and deal with several points at once rather than over months of letters. EM1825 itself acknowledges that meetings can reduce the cost and length of an enquiry. The risk is that HMRC wants to hear from you directly, often about private spending and assets, and anything said is recorded in notes that can be used as evidence before a tribunal (EM1835). Unprepared answers, guesses at personal spending and offhand remarks about cash can all become the basis for further questions or a wider enquiry.

How should you prepare?

EM1835 tells officers to issue an agenda covering the main areas for discussion so that the taxpayer and adviser can prepare, although it need not be an exhaustive list of questions. Use it. Preparation usually means:

reviewing the return, accounts and records for the period with your adviser;
being clear on how takings are recorded, who writes up the books and whether any records have not been seen;
in a full enquiry, assembling details of private bank accounts, assets and regular spending, since EM1840 says officers will want to know the extent of assets and the general level of personal expenditure where the business records look unreliable;
deciding in advance whether there is anything to disclose.

If HMRC wants to discuss a spouse’s or partner’s finances at a joint meeting, EM1830 requires this to be made clear in advance and each person to agree to discussing their personal finances in front of the other; otherwise they are seen separately. Questions about private spending are covered in detail in HMRC questions about private living expenses. The difference between a narrow and a full enquiry is explained in aspect versus full enquiries.

What is the adviser’s role at the meeting?

Under EM1825, if a taxpayer has an agent the agent should be invited, and a meeting should only proceed without them if the agent declines or the taxpayer chooses to go ahead alone. If that happens, HMRC should tell the agent afterwards what was discussed unless the taxpayer objects.

The same guidance tells officers that, unless the question concerns the agent’s own work or a technical issue, they need to hear the answers from the taxpayer, who has first hand knowledge of the business and their private affairs. Officers are told this should not stop the agent asking the client to clarify an answer. In practice the adviser’s job is to keep the discussion within the agenda, ask for a question to be rephrased if it is unclear, deal with technical and accounting points, stop the client guessing figures they do not know, and take their own note. HMRC may also hold a separate meeting with the bookkeeper or accountant about how the records and accounts link together.

Where are meetings held and how are they recorded?

EM1845 says meetings should, where possible, be held at the business premises or the accountant’s office, and that meetings at a private residence should be avoided where possible. When outside the office the officer is an invited guest and must leave if asked. EM1835 says that neither HMRC nor the taxpayer may record audio or video meetings and that officers should refuse a request to video a meeting. Instead, officers keep notes. Where irregularities are found, HMRC should issue the notes to the taxpayer, who can propose amendments in a separate letter; otherwise notes are issued on request. Check them carefully, because they may later be relied on as evidence.

What happens if problems come to light?

EM1850 tells officers to ask, in a neutral way, whether there is anything further the taxpayer wishes to tell them, and to avoid any words that could be construed as a threat. If irregularities emerge, the taxpayer should be given the chance to make a full disclosure. EM1840 says that as soon as an inaccuracy or omission is identified the officer must give the Human Rights Act message in factsheet CC/FS9, explaining the taxpayer’s rights, along with the relevant penalty factsheets, and must explain that cooperation can reduce penalties but that it is the taxpayer’s choice. If the taxpayer is unrepresented and decides to take professional advice, discussions should stop and resume with the adviser present. EM1822 says that if fraud is suspected the officer must end the meeting immediately and follow HMRC’s suspected fraud referral process; one possible outcome is a COP9 investigation.

What happens after the meeting?

EM1855 says the taxpayer should leave knowing where they stand: what further information is needed, by when, and whether additional liability is likely. HMRC should follow up in writing with the details and timetable, with the meeting notes. If the information provided shows the return is accurate, the officer should say so and close the enquiry promptly. If not, settlement may be by amendment, assessment or a contract settlement.

Illustration only. A hairdresser is asked to attend a meeting about cash takings. Her adviser obtains the agenda, reconciles the till records to bankings, and prepares a summary of her household spending from bank statements. At the meeting the officer asks how much cash she spends each week; she starts to guess, and her adviser suggests they confirm the figure from her statements and write in. The notes record that undertaking, and the enquiry closes after a short letter.

What mistakes do people make?

Attending without an adviser, or allowing the adviser to answer questions only the taxpayer can answer.
Guessing private spending figures that later need to be explained away.
Not checking or correcting HMRC’s notes of meeting.
Treating a refusal to meet as ending the enquiry.
Recording the meeting covertly instead of agreeing a careful note.

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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.