CH262500 - How to do a compliance check: authorised officer: classes of authorised officer: issuing an identity unknown notice or identification notice
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.

Only an authorised officer can issue an:
- identity unknown notice
- identification notice
Identity Unknown Notices

An identity unknown notice normally requires the approval of the tribunal but there are exceptions, see CH262200 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch262200).

Where tribunal approval is needed, the application can only be made with the approval of an authorised officer. The authorised officer can only apply to the tribunal after a member of the Senior Civil Service (SCS), has given consent. Consent is required for each case separately.

If the authorised officer agrees with your application, they will seek consent from the relevant SCS member for your directorate.

For identity Unknown notices, the authorised officer must be:
- a Grade 6 in FIS, C-A and RIS or
- the nominated Grade 6 in other business areas
If you think that it is appropriate to issue an identity unknown notice, you should discuss the case with your line manager. If they support your assessment of the situation you must then make a submission to the relevant authorised officer, see CH260500 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch260500).

If you and your manager need further advice, you should contact the Specialist Technical Team (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch910000).

If it is necessary for the authorised officer to apply to the tribunal you will need to work closely with them once they have approved your application. You will normally be responsible for drafting any initial letter, the formal notice and the brief for the tribunal. You should send a copy of the brief for the hearing, with a short submission, to the authorised officer via your line manager.

The authorised officer should consider having a lawyer from HMRC Legal Group attend the tribunal hearing.

Exceptions

Where the identity unknown notice is one that does not require tribunal approval (for example, information about a subsidiary company from its parent, or a partner from another partner) see CH227100 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch227100). SCS consent is not required.

Identification Notices

Tribunal approval is not required for issuing an identification notice, nor does it require consent from a member of the SCS, but it must be authorised and issued by an authorised officer.

The authorised officer must be:
- a minimum of Grade 6 in FIS, C-A and RIS
- a nominated Grade 6 in other business areas