Apply for temporary approval
Source: gov.uk (2025-02-01)

How to apply for temporary approval if your approval has been rejected or revoked in one of the application schemes.

Temporary approval allows your business to continue trading during the review or appeal process if HMRC rejects or revokes your approval in one of the following schemes:
- Alcohol Wholesaler Registration Scheme (https://www.gov.uk/government/publications/excise-notice-2002-alcohol-wholesaler-registration-scheme/excise-notice-2002-alcohol-wholesaler-registration-scheme#revoke)
- Warehousekeepers and Owners of Warehouse Goods (WOWGR) (https://www.gov.uk/government/publications/excise-notice-196-excise-goods-registration-and-approval-of-warehousekeepers-warehouse-premises-owners-of-goods-and-registered-consignors/excise-notice-196-excise-goods-registration-and-approval-of-warehousekeepers-warehouse-premises-owners-of-goods-and-registered-consignors)
- Registered Dealers in Controlled Oil (RDCO) (https://www.gov.uk/guidance/registered-dealers-in-controlled-oil-excise-notice-192)
- Tobacco Duty: Raw tobacco scheme (RTS) (https://www.gov.uk/government/publications/excise-notice-2003-tobacco-duty-the-raw-tobacco-approval-scheme/excise-notice-2003-tobacco-duty-the-raw-tobacco-approval-scheme)
- Tobacco Duty: Tobacco Products Manufacturing Machine Licensing Scheme (TPMMLS) (https://www.gov.uk/government/publications/excise-notice-2004-tobacco-duty-tobacco-products-manufacturing-machine-licensing-scheme/excise-notice-2004-tobacco-duty-tobacco-products-manufacturing-machine-licensing-scheme)
- Fulfilment House Due Diligence Scheme (FHDDS) (https://www.gov.uk/guidance/fulfilment-house-due-diligence-scheme)
- Excise goods in Freeports also referred to as Freezones (https://www.gov.uk/guidance/storing-processing-or-producing-excise-goods-in-a-freeport-customs-site)
- Alcoholic products producer approval (APPA) (https://www.gov.uk/guidance/check-if-you-need-an-alcoholic-products-producer-approval-appa)
Temporary approval:
- is distinct and has different criteria to your original rejected or revoked approval
- is intended to protect your rights to a fair review or appeal hearing
- does not change the original reasons for rejection or revocation and should not be taken as indication that the original decision will be changed
Who can apply

You can apply for temporary approval if both the following apply:
- HMRC has rejected or revoked your approval in one of the areas listed (#schemes-list)
- you have asked for a review of that decision or appealed the decision to the First Tier Tribunal
HMRC will tell you about the option to apply for temporary approval when we send you the revocation decision. You cannot make an application before then.

Before you apply

You must send us the correct evidence to show that you meet the qualifying conditions for temporary approval.

To get temporary approval, you need to show both of the following.

Evidence that the business will not survive

You must include an independent financial report into the business. This must show that the business would not stay viable through the review or appeal process without temporary approval. We cannot accept a statement from the business to say that it will suffer hardship without temporary approval.

An ‘independent’ is a person who:
- has no connection to the applicant
- can provide an objective analysis of the company’s position
An independent financial report will:
- give details of the business’s situation
- provide evidence that the business will not survive until the appeal process has concluded
You must download and return a completed information checklist (https://assets.publishing.service.gov.uk/media/60e42dc4d3bf7f7c2b7f30f0/Information-Checklist__1_.odt) (ODT, 17.5 KB) to make sure that you have provided the correct evidence.

Evidence of prospects in the review or appeal

You must provide a copy of one of the following:
- your letter showing the reasons you have asked for a review of the refusal or revocation
- the details of the formal appeal to the First Tier Tribunal which is challenging the original decision
How to apply

You must apply by email within 30 working days of receiving a refusal or revocation decision. Include your:
- completed information checklist and any information asked for on the checklist
- evidence that the business will not survive (#evidence-of-survivability)
- prospects in the review or appeal (#evidence-of-prospects)
Your email should use the subject line ‘Application for temporary approval’ and contain the following statement:

‘(Insert name of business) wishes to apply for temporary approval to trade pending the review and/or appeal hearing into the recent refusal/revocation decision made by HMRC.’

Send your application and attachments to xxx@xxx.xx (mailto:xxx@xxx.xx).

What happens after you apply

How HMRC makes a decision

We will consider the evidence you have provided and issue a decision based on:
- the financial state of the business with regard to how long it can survive
- the steps taken by the business to protect itself through the appeal process
- the efforts taken to act quickly in all review or appeal processes
- the prospect that the review or appeal will be found in the business’s favour
- any other factor we consider relevant
If you provide the correct evidence with your application, we will aim to make a decision within 30 working days.

What happens when information is missing from an application

We will contact you if you do not send us all the information we need. When this happens:
- the 30 working day target is paused until a we receive your response
- you will have 14 days to reply with the information unless you agree a different timescale with us, or tell us that you will not be sending any more information
If we do not receive the information, the application will be considered without it – this may affect our decision.

If a temporary approval decision is granted

When a temporary approval is granted, we will send you a decision letter. This will include the conditions and any monitoring attached to the temporary approval. You can appeal the conditions to the First Tier Tribunal.

Temporary approval will start from the date of the decision and will end when the review or appeal of the main refusal or revocation has ended. HMRC can vary these conditions or remove the temporary approval if:
- there is evidence that you have breached the conditions
- any new evidence of concern comes to light
If a temporary approval decision is refused

If the temporary approval is refused, we will send you a decision letter and the options to appeal. There is no option to seek an internal review of the refusal decision – appeals must be made straight to the First Tier Tribunal.

What you can appeal

You can appeal to the First Tier Tribunal against:
- a rejected temporary approval application
- conditions placed upon a granted temporary approval
- the varying of conditions or restrictions which the temporary approval is subject to
- a decision to revoke a temporary approval
More information

You can find out more about the temporary email process by emailing xxx@xxx.xx (mailto:xxx@xxx.xx).

Read more about Alcohol Duty in the alcoholic products technical guide (https://www.gov.uk/guidance/alcoholic-products-technical-guide).