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United KingdomGOV.UK

HMRC maps Special Measures path for unco-operative giants

New manual sets the £200m/£2bn scope, the three entry tests with £2m double-risk rule, the 12-month warning and 27-month notice ladder, reissue deadlines and public-naming sanction.

By Taxxa AI OyPublished 2 October 2026

Tax Legal & Corporate

Large businesses that persistently refuse to engage with HMRC now have a published manual mapping the full Special Measures enforcement path.GOV The regime, guided by Schedule 19 Part 3 of the Finance Act 2016GOV, targets a small number of large businesses whose unco-operative behaviour persists and which pose a significant risk to the Exchequer.

Scope turns on size. The legislation covers large UK groups, UK sub-groups of a foreign group, UK companies and UK partnershipsGOV, and a business counts as large where, in the previous financial year, turnover exceeded £200 million or the balance sheet total exceeded £2 billionGOV.

Entry requires three cumulative behaviour conditionsGOV: the business repeatedly demonstrates unco-operative behaviourGOV, some or all of that behaviour contributes to at least 2 significant unresolved tax risksGOV, and there is a reasonable likelihood of similar behaviour recurringGOV. A significant unresolved tax issue means a disagreement (or reasonable likelihood of one) over a UK tax liability of at least £2 million that stays unresolved wholly or partly because of unco-operative behaviourGOV; for UK groups the count runs across the group, and the two issues need not stay the same pair throughout. Speculative positions (interpretations with less than a 50% chance of success) and post-April 2016 avoidance arrangements caught by the listed provisions feed the behaviour assessment.

The notice ladder runs warning, entry, confirmationGOV. A Warning Notice tells the business it may enter Special Measures if behaviour does not improve; it runs 12 months from issueGOV, extendable to 15 months, withdrawable within 15 months, and lapses automatically if a Special Measures Notice follows. A Special Measures Notice, issued 12 to 15 months after an unwithdrawn Warning Notice where behaviour persistsGOV, confirms entryGOV, lasts 27 months unless withdrawnGOV, and exposes the business to sanctions for inaccuracies in documents given to HMRCGOV. A Confirmation Notice extends the regime 27 months where behaviour continuesGOV, issuable 24 to 27 months after the Special Measures Notice; notifications are signed off by a designated HMRC officer following Tax Disputes Resolution Board approval.

A fresh notice can follow expiry where behaviour recurs within 6 monthsGOV, subject to 7/8/9-month notify-represent-issue deadlinesGOV; businesses can make representations at each stage, and HMRC must decide before the standing notice expires.

Public naming sits at the top of the ladder. Once a Confirmation Notice is in force the Commissioners may publish identifying detailsGOV after notifying the business and considering representations; withdrawal or expiry ends exposure and requires a clearance notice within 30 days.

Legal basis: Schedule 19 Part 3 of the Finance Act 2016, as explained in HMRC's Special Measures manual.

If your group exceeds the £200m turnover or £2bn balance-sheet threshold, audit HMRC engagement for persistent non-cooperation and use the 12-month warning window and representation rights before entry hardens.

Sources