ECSH33910 - Notes of meeting
Source: gov.uk (2025-02-14)


Using your contemporaneous notes of meeting, you should create a set of typed notes of meeting (sometimes internally referred to as ‘NOMs’) that will be shared with the business. The purpose of this is to resolve any misunderstandings quickly, and so both parties have an accurate record of the meeting. This saves time further down the line if something has been misunderstood and provides evidence for considering the outcome of the intervention.

If the second officer acted as notetaker during the compliance intervention, you might ask them to type up the notes from their notebook, but usually it is the caseworker who will type up the NOMs, as they understand the risks that are present and what evidence they need to get agreed by the business and its representatives.

How to write notes of meeting

The NOMs don’t need to be word for word, but they should be an accurate representation of the meeting, not a short summary. For example, a five-hour meeting are likely to be longer than two pages of A4 notes of meeting, as there would have been more discussed in the meeting and recorded in your contemporaneous notes. Sentences such as ‘we had a general conversation about risk’ will not help you evidence a potential breach and must be avoided.

All the information contained in the contemporaneous notes of meeting needs to be covered in the NOMs shared with this business. This is because it is your evidence and if it has not been presented to the business, it cannot be relied upon later, for example to support a sanction, or to be produced as evidence in criminal or civil proceedings. This includes information discussed during any records testing, and an accurate description of any documents or records you saw whilst in the meeting, for example, ‘training completion certificate for Joe Bloggs dated 31 March 2022’, or ‘invoice number 123 dated 6 January 2024’.

If you have handwritten notes, you may want to type up an identical version of the original notes and then cut and paste them into a logical order. However, sometimes it is important to show the flow of a meeting, for example if the business owner changes their original response to a topic later in the meeting, you would want to show the initial responses and later sudden changes.

You must not include sensitive information, such as information from customer ID documents or bank account details in the NOMs issued to the business. This is in case they are intercepted by someone other than the intended recipient, especially when using email. They should be captured in the contemporaneous notes of meeting, with reference made to them in the NOMs. For example, “details of driving licence recorded in Officer Smith’s notebook.” or “bank account ending 456”.

There isn’t a template for NOMs; you must make sure they are easy to read using the best practice below. They must show at the top:
- The business name.
- Caseflow reference.
- Supervised sector.
- Address visited or phone number called.
- Date of the visit or phone call.
- Start and end times of the visit or phone call.
- Names of everyone present during the visit/call and their role, or if an independent advisor is present, the company they work for.
Best practice

As best practice, you should:
- Type up your contemporaneous notes as soon as possible, within 48 hours to form the basis of your NOMs.
- Record both the question and the response, making it clear who said what.
- Redact sensitive information such as bank/ID details.
- If something may be contentious or is likely to be used as evidence of a breach, write it out as verbatim as possible.
- Type acronyms/abbreviations in full the first time used, with the abbreviation in brackets. Do not use any uncommon abbreviations
- Use “quotes” for important statements that are recorded word for word.
- Use initials sparingly as they can make it hard to read - consider using a shortened form of the business name rather than more initials.
- Be consistent in the use of tenses and/or persons.
- Use HMRC style guide – particularly for dates and numbers see Our writing and style guide – HMRC.
- Use headings and paragraph/line numbering to assist future reference for example, to cross reference to penatly documentation.
- NOMs must not contain unsolicited, unprofessional, or offensive comments. Any comments which you think are relevant beyond what was actually said must be recorded separately within Caseflow.
Finalising notes

If you know that a topic was discussed which you need to include in your NOMs but was not recorded in the contemporaneous notes of meeting, you should include it in your NOMS and add a new entry in your notebook, explaining that it was omitted at the time. Follow the guidance at CH204510. (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch204510)

Retaining and recording notes

For guidance on retaining and recording notes, follow the guidance at CH204510 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch204510).

Sending copies of notes to the business

Typed copies of the NOMs should be sent to the business within 10 working days. You must plan sufficient time for the NOMs to be agreed before you send them to the business as follows:
- The second officer on your visit must review your NOMs and agree they are an accurate representation of the meeting, and correctly reflect any points they recorded in their notebook.
- Your manager may need to approve your NOMs before you issue them to the business – please discuss this with your manager.
Send the NOMs by post or email (if written consent has been agreed with the business) with a covering letter found in the Knowledge Library.

It is good practice to confirm the business has received the NOMs and provide them with the opportunity to correct any errors. If you do not receive any comments, you can assume they have been agreed, as set out in the covering letter. Depending on the circumstances of the case, you might want to ask the business for their agreement and signature, and this should be mentioned during the meeting.

If you are sending the NOMs by email, ensure you convert the files to PDF so they cannot be amended. Digital agreement to the NOMs is acceptable.

If you are sending the NOMs by post and require them to be signed by the business, you will need to enclose two copies of the NOMs and ask in the covering letter that they sign one of the copies and return it to you by the agreed date, factoring in postal times.

Information provided by a money service business (MSB) agent relating to another MSB, must not be recorded in NOMs if they are being sent to the principal, but can be included if sending them directly to the agent. See ECSH32635 .

What if the business does not agree with the notes of meeting?

As you will have sent the business a copy of the NOMs, any amendments which the business wishes to make will be set out in a separate document to your original version.

This should be uploaded to the document store on Caseflow.

You should try to resolve any issues and provide an amended version where appropriate, but ultimately if a business is trying to deny they said something or change what they said, you would acknowledge their disagreement but explain why the notes will not be amended. This highlights the importance of the accuracy of your contemporaneous notes of meeting.