CH270500 - How to do a compliance check: penalties for failure to comply with notices: creating penalty charges
Source: gov.uk (2025-12-05)


This page and chapter are under review as the relevant content is also published in the technical guidance chapters of the Compliance Handbook (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook), within Compliance checks factsheets (https://www.gov.uk/government/collections/hm-revenue-and-customs-compliance-checks-factsheets) and in Compliance checks guidance (https://www.gov.uk/guidance/hmrc-compliance-checks-help-and-support). If you use particular pages regularly, please email xxx@xxx.xx (mailto:xxx@xxx.xx) to let us know the specific content you find useful.

Penalties are raised using the National Penalties Processing System (NPPS). You will use SEES to create and send the relevant penalty notice.

As soon as you are ready to assess the penalty you will need to seek authorisation from your authorising officer via NPPS. NPPS will need to know what reference number to use to raise the penalty charge. Take care that the reference number relates to the right person, see CH21580 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch21580), in ETMP. The person will need a SAFE record to enable NPPS to raise the charge.

For example, a partnership does not have a tax position for income tax, but it does for VAT. For income tax a penalty assessment is made on the nominated partner, so NPPS will require the nominated partner’s IT Unique Taxpayer Reference (UTR) or National Insurance Number (NINO). For VAT, NPPS will require the partnership VAT Registration Number.

Similarly, you need to identify the correct person if you charge a penalty on a third party.

For example, you want to charge a penalty on ABC (Holdings) PLC and find an employer’s (BROCS) reference for ABC Group Payroll. You would not be able to use the BROCS reference because it is not for the correct entity (person). You would need to find the corporation tax reference (CT UTR) or VAT Registration Number for ABC (Holdings) PLC.

Primary area of the compliance check

Reference to use

Income Tax and CGT

IT Unique Taxpayer Reference (UTR), or National Insurance Number (NINO) - search for this in ETMP following the guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

Corporation Tax

CT Unique Taxpayer Reference (UTR) - search for this in ETMP following guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

Pension Schemes

IT UTR or CT UTR - search for this in ETMP following guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook). If, exceptionally, you cannot find a suitable reference you should email DL-Safe Unit Technical Team (mailto:DL-Safe Unit Technical Team) - search for this in ETMP following guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

PAYE/NIC/CIS

BROCS reference - search for this in ETMP following guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

VAT - Registered Trader

VAT Registration Number (VRN)

VAT - Non-registered Trader, Insurance Premium Tax, Stamp Duty Land Tax, Stamp Duty Reserve Tax, Aggregates Levy, Climate Change Levy, Landfill Tax

use one of the following: the CT UTR, the IT UTR, the VRN, the BROCS (employer’s) reference, or, for individuals, a NINO - search for this in ETMP following the guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook). If, exceptionally, you cannot find a suitable reference after trying all of the above you should email DL-Safe Unit Technical Team (mailto:DL-Safe Unit Technical Team) - search for this in ETMP following the guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

Inheritance Tax

NINO - If you cannot use a NINO, email DL-Safe Unit Technical Team (mailto:DL-Safe Unit Technical Team) - search for this in ETMP following the guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

Petroleum Revenue Tax

the PRT reference

Failure to comply with an information notice under s118BA, CEMA79

use one of the following: the first 9 digits of the DTRN (the VRN), the CT UTR, the IT UTR, the BROCS (employer’s) reference, or, for individuals, a NINO. If, exceptionally, you cannot find a suitable reference you should email DL-Safe Unit Technical Team (mailto:DL-Safe Unit Technical Team) - search for this in ETMP following the guidance in the Searching for a Taxpayer (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)