CH206125 - How to do a compliance check: starting a compliance check: sensitive cases
Source: gov.uk (2025-09-01)


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.

Overview

These instructions apply to all Customer Compliance Group cases.

The sensitivity of a case depends on the level of risk it poses to HMRC and the likelihood of that risk occurring.

A case may become sensitive at any time during a compliance check. A case is sensitive if it is likely to generate significant:
- ministerial interest
- political embarrassment
- reputational damage to HMRC
- national media and social media coverage
This guidance is for sensitive cases only, not customers who need extra support. For information on customers who need extra support please follow CH201360 (https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch201360).

Factors which could influence whether a case is sensitive or not include cases that:
- relate to high-profile individuals or public institutions such as banks/financial institutions where publicity would adversely impact upon HMRC
- relate to financial sanctions imposed on entities by the UK following decisions made by the United Nations or European Community
- use innovative or undercover approaches to case development where there is a risk of the case being compromised
- contain political issues or high-profile departmental campaigns
- contain terrorism, corruption or national security related issues
- contain export licensing involving military or strategic goods
- use covert techniques which could generate adverse publicity
- contain large tax losses or risk to the revenue which could have been avoided
- have had lengthy or costly investigations that are likely to be criticised as disproportionate to the offence
- offer immunity to a potential prosecution witness where evidence is available
- contain commercial contracts which impact HMRC or other government departments
- have a risk or appeal lodged due to procedural failure, including incorrect application of the law
Involvement in one or more of these factors does not automatically make a case ‘sensitive’, if the interaction is routine or considered low-risk. Similarly, if your case does not involve any of the factors listed above but you feel it should be dealt with as a ‘sensitive’ case, please talk to your sensitive case SPOC or CCM for direction.

The following cases are NOT considered as sensitive:
- cases involving HMRC employees
- complex or innovative legal procedures - for example, a case using a new piece of legislation or unusual liability issues
You should also consider whether one case that in isolation looks sensitive but low-risk could in fact be sensitive and high risk if there is evidence that several similar cases are connected. For example, a group of companies or individuals could be linked by the same political issue or high-profile departmental campaign. Again, this list is not exhaustive. If you believe this may be an issue, please discuss it with your Sensitive case SPOC or CCM.

The designation of a case as ‘sensitive’ doesn’t mean that it’s marked for special treatment or that such a designation should be applied throughout the lifetime of the case. When the designation is no longer necessary it should be removed. If a case is ‘sensitive’ at the time of closure, it will retain this classification for file retention purposes.

If you are allocated a sensitive case or a case becomes sensitive while you are working it, you need to report it so it can be monitored.

How to report a sensitive case

It’s for the business to decide whether any operation should be reported as a sensitive case. This can be at any time during the compliance check, in line with CCG sensitive case management procedures which can be found within your business area tile on the CCG Guidance Hub.