EM1604A - Opening the Enquiry: communications: timing of issue of factsheets
Source: gov.uk (2025-09-29)


You must give the taxpayer the relevant factsheet at the appropriate stage of the enquiry. The factsheets do not explain everything about a subject but do give the taxpayer essential information.

If a taxpayer requests a factsheet at any stage during an enquiry you should give it to them. Otherwise you must issue the factsheets as follows.

CC/FS1 - (a, b and c) – General information

These give general information about HMRC compliance checks. You must issue the relevant general information factsheet, normally with your opening letter.You must issue the appropriate general information factsheet:
- issue CC/FS1a if you don’t work in a Compliance Centre or deal with Large Businesses, or
- issue CC/FS1b for Compliance Centre checks, or
- issue CC/FS1c for Large Business checks, in LBS, and Large and Complex or Public Bodies with CRMs.
For further guidance, CH202050 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202050)

CC/FS2 - Information notices

This explains what an information notice is and when we use them. You must issue this when you issue an information notice. You must not issue it with your opening letter unless you are including an information notice, see CH20200 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch20200).

For further guidance, see CH202025 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202025)

CC/FS3 - Visits - by agreement or with advanced notice

This explains agreed and pre-arranged visits to business premises and why we may need to look at business records or assets. You must issue this before an agreed visit, or before a visit where advanced notice has been given, see CH20250 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch20250).

For further guidance, see CH202125 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202125)

CC/FS4 - Visits - unannounced

This explains why we may need to make unannounced visits to business premises and sets out the taxpayer’s rights.

You must issue this with the inspection notice, when you serve it.

For further guidance, see CH202150 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202150)

CC/FS5 - Visits - unannounced - tribunal approval

This explains why we may make an unannounced visit, with tribunal approval, to business premises and sets out the taxpayer’s rights.

You must issue this with the tribunal approved notice, when you serve it.

For further guidance, see CH202175 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202175)

CC/FS7a - Penalties for inaccuracies in returns and documents

This explains about penalties for inaccuracies in returns and documents, the penalty ranges, how they are calculated, and what a taxpayer can do to reduce a penalty.

You must issue this when you have established that there is an inaccuracy in a return or document and that this may result in potential lost revenue.You must issue CC/FS7a and any other penalty factsheets either at the same time as or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202235

CC/FS7b - Penalties for not telling us about an under-assessment

This explains about penalties for under-assessments, the penalty range, how the penalties are calculated, and what a taxpayer can do to reduce a penalty.

You must issue this when you have established that there is an under-assessment and the person failed to take reasonable steps to tell us about it within 30 days.

You must issue CC/FS7b and any other penalty factsheets either at the same time as or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202245 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202245)

CC/FS9 - The Human Rights Act and penalties

This explains the taxpayer’s rights under Article 6 of the European Convention on Human Rights when we are considering whether we may charge penalties. You must issue this when you find something wrong during an enquiry and have an evidence-based reason to believe that the taxpayer may be liable to a penalty,see CH300700 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch300700).

You must normally issue the relevant penalty factsheets, CC/FS7a, FS7b, FS11, FS15, FS18 (a or b), or FS19 together with or after you have issued factsheet CC/FS9.

If you issue FS9 together with any other factsheets, it is good practise for your covering letter to refer to CC/FS9 before it mentions any penalty factsheets.

For further guidance, see CH202275 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202275)

CC/FS10 Suspending penalties for careless inaccuracies in returns or documentsThis explains what happens when we consider suspending penalties for careless inaccuracies. You must issue this when we have established that there is a careless inaccuracy and you are considering whether the resulting penalty can be suspended.

For further guidance, see CH202300 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202300)

CC/FS11 Penalties for failure to notify

This explains when we may charge a penalty for a failure to notify, the penalty ranges for different types of disclosure and behaviour, and what the taxpayer can do to reduce the penalty. You must issue this when you have established that there is a failure to notify and that this may result in potential lost revenue.

You must issue CC/FS11 and any other penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202325 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202325)

CC/FS13 Publishing details of deliberate defaulters (PDDD)

This explains when we can publish the details of deliberate defaulters and the process we must follow before we can do this. You must issue this before you start to discuss the possibility that a person’s details may be published or when you have an evidence-based reason to believe that there is a deliberate inaccuracy or failure and the PLR may exceed £25,000.

In some circumstances it will be appropriate to issue CC/FS13 at the start of a compliance check, for example where a person has made a disclosure of deliberate behaviour in response to the information about PDDD in CC/FS1 (a, b or c).

You must issue CC/FS13 and any penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202375 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202375)

CC/FS14 Managing deliberate defaulters

This explains when we can include a taxpayer in our programme for monitoring deliberate defaulters. You must issue this as soon as you have an evidence based reason to believe that a person deliberately did something wrong that may result in a penalty for deliberate behaviour.

You must issue CC/FS14 and any penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202400 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202400)

CC/FS15 Self Assessment and old penalty rules

This explains about ‘old’ penalty rules for Self Assessment, and how we reach settlements in direct tax enquiries. It replaces booklet IR160. You must issue this when you have established that there is an inaccuracy or failure and the person may be liable to a penalty under TMA1970 or FA1998, see EM4500.

You must issue CC/FS15 and any other penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202425 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202425)

CC/FS17 Penalties for income tax and capital gains tax involving offshore matters

This explains the higher penalties we can charge for inaccuracies, failures to notify, and deliberately withholding information relating to offshore matters. You must issue this together with the relevant penalty factsheets, CC/FS7a, FS11, or FS18a.

You must issue CC/FS17 and any other penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202455 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202455)

CC/FS18a Late filing penalties for income tax and capital gains tax

This explains when we may increase the penalty percentage of the second further late filing penalty for deliberately withholding information by failing to file Self Assessment (SA) return. You must issue this when you have reason to believe that a person deliberately withheld information that would have helped us to establish their correct tax liability, by failing to file their SA return within 12 months of the filing date.

You must issue CC/FS18a and any other penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202460 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202460)

CC/FS18b Late filing penalties for the construction industry scheme (CIS)

This explains when we may increase the penalty percentage of the second further late filing penalty for deliberately withholding information by failing to file a return. You must issue this when you have reason to believe that a person deliberately withheld information that would have helped us to establish any liability to make payments, by failing to file their CIS return within 12 months of the filing date.

You must issue CC/FS18b and any other penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202465 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202465)

CC/FS19 Employer and contractor returns and old penalty rules

This explains about ‘old’ penalty rules for Employer Compliance reviews and checks on employers and contractors. You must issue this when you have established that an employer or contractor may be liable to a penalty under the ‘old’ penalty rules, see COG914000 (https://www.gov.uk/hmrc-internal-manuals/compliance-operational-guidance/cog914000).

You must issue CC/FS19 and any other penalty factsheets either at the same time or after you have issued factsheet CC/FS9 - The Human Rights Act and penalties.

For further guidance, see CH202470 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202470)

CC/FS22

This explains about sending HMRC Electronic Records. You must issue this if you have requested any Electronic Records.

For further guidance, see CH214000 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch214000)

DSC1 and DSC2

These are available in SEES and explain about communicating with HMRC by E-mail or Dropbox . You should issue these if the taxpayer indicates they wish to communicate using E-mail or Dropbox

For further guidance, see CH206160 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch206160)

HMRC1 HMRC decisions - what to do if you disagree

This explains what taxpayers can do if they do not agree with a decision that they can appeal against. You must issue this if the taxpayer wants more information about their appeal rights. If you issue the HRA message in factsheet CC/FS9 in a meeting you should have a copy of HMRC1 available in case the taxpayer requests it, but you should not issue it unless they ask. Do not issue HMRC1 routinely with decision notices.

For further guidance, see CH202475 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch202475)