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United KingdomGOV.UK

HMRC bars pre-‘final’ publication and caps first publication at 12 months

No publication before a penalty is ‘final’; no first publication more than 12 months after the date it became ‘final’; one year maximum on display.

By Taxxa AI OyPublished 15 September 2026

Tax

HMRC's new guidance page on publication time limits sets two clocks for naming tax advisers penalised for sanctionable conductGOV: when details may first go up, and when they must come down. HMRC must not publish information about a tax adviser before the day on which the penalty becomes ‘final’, or the latest day on which the penalty becomes ‘final’, and the information cannot be published for the first time more than 12 months after the date on which the penalty became ‘final’. Once up, details may stay published for one year from the date of initial publication, and no longerGOV.

Finality has a fixed meaning. A penalty becomes ‘final’ on the day after the end of the appeal period if the person does not make an appeal, or the date when an appeal is finally determinedGOV. That definition drives both clocks: the earliest lawful publication day and the 12-month outer limit for first publication both run from the penalty becoming ‘final’, and the one-year display period runs from the actual initial publication dateGOV.

The time-limits page sits inside the wider publication regime. HMRC must publish the details of a tax adviser issued with a sanctionable-conduct penalty of more than £7,500, and cannot publish where the penalty was set at the £7,500 minimum; there is no right of appeal against the decision to publish. Publication happens on the GOV.UK website in whatever manner HMRC considers appropriate, and a separate page governs what information may be published. The footers cite FA12/SCH38/PARA28 as amended alongside FA09/S94 subsections (7)-(9) for the time limits, with the duty page additionally citing FA26/SCH22/PARA20.

For an adviser facing a sanctionable-conduct penalty, the practical shape is therefore: no publication while the penalty can still be appealedGOV; an outer limit of 12 months after the date on which the penalty became ‘final’ for publishing the information for the first time; and details that can only continue to be published for one year from the date of initial publicationGOV. An adviser who settles at the £7,500 minimum stays out of publication entirely, while any penalty above that threshold carries the duty — with the timing governed by the appeal outcome rather than the penalty dateGOV.

Legal basis: FA12/SCH38/PARA28 as amended; FA09/S94 (7)-(9); FA26/SCH22/PARA20 (duty page).

Diary the finality date on any sanctionable-conduct penalty above £7,500: no publication before it, first publication only within 12 months after it, display for one year at most.

Sources