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United KingdomGOV.UK

Excise due diligence swaps warehouse receipt risk flag

Excise risk list drops unapproved-owner flag for a third-party receipt from a footprint-less business.

By Taxxa AI OyPublished 3 November 2026

Tax

Industry: Warehousing and storage

HMRC has swapped one excise due-diligence risk indicator for another in its compliance-visit guidance on the identity of the business being traded with. The removed line treated it as a risk where a warehousekeeper had been asked to receive goods for a business not approved as a registered owner under the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 when approval should have applied.GOV The replacement treats it as a risk where a warehousekeeper has been asked by a third party to receive goods on their behalf from a business with no obvious business footprint.GOV

The surrounding identity checks are unchanged.GOV Officers still look for lack of supplier identity detail such as missing address or HMRC approval numbers, mismatch with Companies House records, no general visibility of the intended trading partner, partly completed application or trading forms, and high-value goods traded from short-term lease or residential addresses. The new line adds two practical flags to that set: layering through a third-party receipt request, and a counterparty whose commercial presence cannot be verified.GOV

The change concerns the guidance list.GOV What changes is what HMRC lists as a warning sign on a compliance visit: instead of the formal absence of registered-owner approval, a substantive absence of footprint combined with an intermediated receiptGOV.

Warehousekeepers should update due-diligence checklists to capture the new test: a third-party request for receipt and the footprint of the business the goods come fromGOV.

Compliance teams should brief staff on the wording shift and align escalation thresholds so the new third-party receipt and footprint risk indicator is recognisedGOV. The list sits in the excise due-diligence compliance-visit guidance on the identity of the business they are trading with. The legal basis is the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 on approval and registration, applied through HMRC excise due-diligence guidance EDDC03120 on identity risks.

Update excise checklists to the new third-party receipt and footprint risk indicator.

Sources