1: Modernising HMRC’s approach to wealthy compliance 

HMRC has published a plan explaining how it intends to modernise its approach to ensuring that wealthy taxpayers meet their tax obligations. This follows the publication of a report by the National Audit Office (NAO) in May 2025 in which the NAO called on HMRC to “develop a clear strategic vision and plan for its work tackling wealthy non-compliance".

In its plan, HMRC explains the progress it has made since May 2025, and sets out the work still to do (in the form of commitments), across seven themes, as summarised below: 

• Improving its understanding of wealthy customers and enhancing its approach to customer segmentation. HMRC commitment: to bring together data from HMRC systems and third parties "to provide a more in-depth and holistic view of wealthy customers and their connected interests".
• Using better data, digital services and technology to prevent errors and identify risk earlier. HMRC commitment: to use data and AI to " identify emerging risks earlier and target compliance activity where it will have greatest impact".
• Tailoring its compliance approaches to different customer circumstances and risk. HMRC commitment: to use insight to develop "targeted approaches for different groups of wealthy customers". 
• Investing in its people and capability. HMRC commitment: to build specialist expertise in a range of areas including wealth management, family offices and offshore structures.
• Improving customer experience and delivering better compliance outcomes. HMRC commitment: to "improve the quality, timeliness and professionalism" of its compliance work while strengthening its efforts to "identify and tackle deliberate non-compliance and fraud" and ensure tax is paid on time.
• Working in partnership with customers, agents and external partners. HMRC commitment: to support "compliant agents and intermediaries while using strengthened powers and coordinated intelligence to act against those who enable non-compliance".
• Measuring progress and increasing transparency. HMRC commitment: to improve "confidence in the wealthy tax gap estimate and publish a standalone offshore tax gap estimate". 

HMRC’s plan makes reference to its “enhanced billionaire approach”, under which “every identified billionaire with a UK tax footprint has been allocated a CCM (customer compliance manager) and offered a voluntary initial or pre-filing discussion”. Some of ICAEW’s members have reported that their clients have received letters from HMRC.  

HMRC says that it “will assess both the wider CCM approach and the specific experience of billionaires... to improve how CCM resource is targeted, how oversight is delivered and how effectively the model supports earlier, more coordinated and proportionate intervention”.

2: Addressing non-compliance by larger businesses 

The government has said that it will "review its approach to persistent non-compliance and egregious behaviour by a small minority of larger businesses", engaging with stakeholders on any potential changes.  

The review will include the special measures regime (Finance Act 2016, s161 and Sch. 19, part 3), introduced in 2016, under which HMRC can impose sanctions on " large businesses with an ongoing history of aggressive tax planning and/or refusing to engage with HMRC". In a report published in July 2026, Parliament's Public Accounts Committee noted that HMRC had yet to put a large business into special measures, potentially undermining the regime’s role as a deterrent.   

Further information 

• Budget 2026 – Breathing Space for today, Fresh hope for the future (paragraph 6.165) 

3: Making better use of property income data 

The government has published a consultation document seeking views on proposals to reform the reporting of property income data to HMRC by letting agents and tenancy deposit scheme providers. The government hopes that "high-quality, timely and identifiable third-party data" on property income will help "HMRC to deliver better services for taxpayers while strengthening compliance activity".

The initiative is part of the government's phased approach to reforming how HMRC acquires data from third-party sources, which began with the reporting of interest income data and card sales (merchant acquirer) data.  

4: Improving tax intermediary markets 

The government intends to publish a roadmap in spring 2027 "setting out HMRC’s long-term approach to working with tax advisers, software providers and others that support taxpayers to interact with the tax and customs system". 

This is expected to include:  

• strengthened standards for tax software providers; 
• measures to help HMRC "tackle harmful intermediary activity, including through a clear route for reporting harmful activity to HMRC"; and 
• HMRC's approach to "tackling tax misinformation and incorrect tax advice online". 

Further information 

• Budget 2026 – Breathing Space for today, Fresh hope for the future (paragraph 6.158)
• Standards for tax software to be strengthened | ICAEW 

5: Tackling the tax avoidance market

The government has said that it "will shortly publish a consultation on a package of measures to tackle the promotion and use of tax avoidance", including: 

• new powers for HMRC to tackle serious and serial users of tax avoidance schemes;
• changes to enable earlier recovery of promoters’ and certain individuals’ liabilities; and
• changes to further strengthen the promoters of tax avoidance schemes regime. 

Further information 

• Budget 2026 — Overview of tax legislation and rates (OOTLAR) - GOV.UK