HMRC Charter consultation: summary of responses
Updated 5 November 2020
1. Background
HMRC deals with the tax and payments affairs of almost every business and individual in the UK.
The HMRC Charter is a legal requirement under the Finance Act 2009. The legislation states that the Charter ‘must include standards of behaviour and values to which Her Majesty’s Revenue and Customs will aspire when dealing with people in the exercise of their functions’.
HMRC is committed to improving its customer experience and proposes that HMRC’s Charter is used to define the service and standard of behaviour that customers should expect when interacting with us.
HMRC published a public consultation on a new draft charter on 24 February 2020. This was due to close on 15 May 2020 but, in line with wider HM Treasury and HMRC consultations, the closing date was extended due to the impact of COVID-19 until 15 August 2020.
HMRC invited general comments on the draft HMRC Charter or feedback limited to particular areas but also provided some questions to help respondents structure their feedback:
- do you think the draft Charter sets the right standards for HMRC’s service to customers?
- to what extent do you feel the draft Charter sets out the areas that are most important to customers when interacting with HMRC?
- how you would like to see HMRC measure and monitor how it is performing against the Charter, including how we can best listen to feedback and make improvements?
HMRC engaged widely during the consultation to ensure they heard a range of views, for example:
- formed a representative Charter Steering Group with a selection of external stakeholders from the tax professional community to advise directly on the consultation - see Appendix 1 for list of the members
- presenting at numerous external stakeholder groups
- ran 6 focus groups to hear direct from HMRC customers
- within HMRC, ran frontline staff focus groups, promoted the consultation internally and attended key internal senior leadership meetings
HMRC is grateful for the engagement of stakeholders in this consultation. We received over 50 responses to the consultation from a selection of individuals, tax professionals and our own people, including detailed submissions from many tax professional stakeholders and organisations.
HMRC has taken account of responses and made a number of changes to the final Charter which it has published today.
2. Executive summary
A list of organisational respondents and links to their full submissions, where published, are provided in Appendix 2.
In summary, the key areas of feedback were around:
- content and tone
- visibility, internally and externally
- measurement and oversight
Content and tone
While the majority of respondents recognised the benefits of the more accessible and human tone in the draft Charter, many tax community stakeholders also felt the Charter standards had been diluted as a result. They asked for the language to be strengthened in some areas and for some wording from the previous Charter to be reinserted.
Visibility internally and externally
There was a consistent view that the previous Charter was not well known enough externally by customers and not embedded enough within HMRC. Several respondents made the point that this was in many ways more important than the wording of the Charter.
Measurement and oversight
There was strong feedback that measures could be broadened – even if just linking more overtly to customer experience data already published. There was a strong theme from the tax professional community in particular that HMRC was not accountable enough when it failed to meet standards, and that the Customer Experience Committee should be more “independent” in its role in overseeing the Charter and lacked perspective from those who deal with HMRC on a daily basis.
3. Government response
HMRC has reviewed the consultation responses and has today published a final revised HMRC Charter, taking into account the feedback received, as set out below.
For reference, you can read:
- the draft version of the HMRC Charter that was put out to consultation
- the previous charter, ‘Your Charter’, which has been archived but is still available to read on GOV.UK
Content and tone
In line with feedback from the consultation, the final Charter retains the accessible feel and the structure of the draft Charter. Respondents to the consultation attached significant importance to embedding the Charter within HMRC. We feel the headings and tone in the final Charter will prove beneficial in helping achieve this, supported by the Compliance Professional Standards (see below) which are being developed to match the structure of the new Charter.
However we have also reinserted some of the detail in the previous Charter which respondents felt most strongly about. One of the most consistent requests from tax professional stakeholders was to retain the previous Charter’s commitment to ‘Accept that someone else can represent you’. We have reinserted this standard (changing the wording slightly to ‘Recognising that someone can represent you’) into the new Charter, with an added reference to the standards expected of professional tax agents.
Other examples of where we have added wording back in are the commitment to ‘make sure that the people you deal with have the right level of expertise’ (under Being responsive) and ‘minimising the cost to you’ (under Making things easy).
In other areas, we have strengthened the language in line with feedback received, in particular changing ‘aim to’ to the stronger ‘will’. For example under Getting Things Right we have amended ‘we’ll aim to provide you with accurate, consistent and clear information’ to ‘we will give you accurate, consistent and clear information’.
Although some tax professional stakeholders recommended retaining the separate list of ‘customer obligations’ in the previous Charter, this was not a universal view so we have not reverted to this structure. Instead we have continued to refer to customer obligations within the new Charter text, for example under Getting Things Right: ‘When we ask for information, we rely on you to give us full, accurate and timely answers’. Mutual respect is important in the interactions between HMRC employees and customers. We have retained this section in the final Charter, with an emphasis on both parties treating each other with respect and integrity.
Embedding the Charter
To reflect feedback that the Charter could be more visible both inside and outside HMRC, we have been considering how to ensure that the standards in the new Charter are more embedded within HMRC’s day to day business. For example:
- we are developing a set of Compliance Professional Standards structured around the Charter standards which will ensure that taxpayers’ individual circumstances are considered in compliance enquiries
- we have published key principles for customers who need extra help which underpin and provide more detail on the Charter’s commitment to “give you extra support if you need it”
We are also linking the Charter principles into policy development, the tax professionalism programme, design principles, digital usability and quality assurance procedures in our customer service work.
Measures
It is important that any Charter measures support HMRC’s strategic objectives and are consistent with HMRC’s wider performance indicators. We will ensure that the Charter measures continue to reflect HMRC’s wider performance framework.
Currently the Charter is measured through questions in the Annual Customer Survey which are included in the Charter Annual Report. In line with feedback we are continuing with these measures but also signposting more clearly to other customer experience data already published by HMRC. This will provide a broader and more visible picture of performance against the Charter.
Oversight and transparency
HMRC puts great emphasis on feedback on its performance against the Charter so that it can use it to improve the service it provides. On the Charter page on gov.uk, HMRC encourages customers to tell us about their experiences interacting with HMRC and to make a complaint if they are not satisfied that the Charter standards have been met.
The Customer Experience Committee has an important role in bringing together customer experience expertise to support and challenge ExCom on customer experience-related issues and to help the department deliver on its strategic objectives. It complements the existing wider external stakeholder forums HMRC already runs.
Following the valuable feedback they provided during the consultation, we plan to continue consulting quarterly on Charter performance with the representative Charter Stakeholder Group. Feedback from these meetings will be fed into a new Charter performance review with the Customer Experience Committee each quarter. The recent addition of the Adjudicator to the Customer Experience Committee, also requested by some consultation responses, will also provide added external perspective to the committee discussions.
For the first time HMRC is also committing to publishing a forward looking customer experience plan each year in response to the Charter Annual report, beginning with the 2020 to 2021 Charter Annual report due to be published in the summer of 2021.
Training
It is important that HMRC employees are supported to deliver the standards in the Charter so they can turn the good intentions into improvements that customers can feel and benefit from. We are working across HMRC business areas to build priority skills mapped against our Charter standards, including empathy, writing in customer language and supporting customers who need extra help.
We have delivered new training material related to the Charter, which has been accessed 40,000 times by HMRC staff so far this year, and we are continuing to develop and roll out new modules.
Appendix 1: Charter Stakeholder Group
- Rebecca Benneyworth – Administrative Burdens Advisory Board
- Susan Cattell – Institute of Chartered Accountants of Scotland
- Glen Collins – Association of Chartered Certified Accountants
- Samantha Mann – Chartered Institute of Payroll Professionals
- Caroline Miskin – Institute of Chartered Accountants in England and Wales
- Will Silsby – The Association of Taxation Technicians
- Claire Thackaberry – Low Incomes Tax Reform Group
- Richard Wild – The Chartered Institute of Taxation
Appendix 2: list of organisational responses
- Association of Accounting Technicians - read their response
- Association of Certified Chartered Accountants
- Association of Disabled Professionals
- Association of Taxation Technicians - read their response
- Bernard Rogers & Co Chartered Accountants
- BDO LLP
- Buffery & Co
- CFE Tax Advisers Europe
- Chartered Institute of Taxation - read their response
- Chartered Institute of Payroll Professionals
- DWF Law LLP
- Field Court Tax Chambers
- Institute of Chartered Accountants in England and Wales (ICEAW) - full response is at the following link (you may need to paste into browser) www.icaew.com/-/media/corporate/files/technical/icaew-representations/2020/icaew-rep-50-20-hmrc-charter
- Institute of Certified Practising Accountants - read their response
- Institute of Chartered Accountants of Scotland (ICAS)
- Institute of Financial Accountants - read their response
- KPMG
- Low Incomes Tax Reform Group - read their response
- Northern Ireland Tax Committee of Chartered Accountants Ireland
- PricewaterhouseCoopers
- Royal Association for Deaf people
- RSM UK Tax and Accounting Limited
- Saffery Champness LLP - read their response