Consultation outcome

Improving the data HMRC collects from its customers – Summary of responses

Updated 27 April 2023

Executive Summary

Background

The consultation, ‘Improving the data HMRC collects from its customers’ was published in July 2022 and was open for responses until October 2022. The government would like to thank all respondents for the time and effort in engaging with the consultation process and their invaluable feedback. This document summarises the responses to the consultation and sets out the government response and next steps.

The consultation proposed a number of options for improving the range of data HMRC collects, uses and responsibly and safely shares across government. In that consultation we presented 6 options where collecting additional data could bring significant benefits to customers and taxpayers when balanced against any potential additional administrative burden for customers. Some options target specific customer groups, such as the self-employed, while others look to collect a particular piece of information across different customer groups. These were:

1. the business sector of the self-employed
2. the occupations of employees and the self-employed
3. the location of an employment or a business
4. the hours employees work
5. dividends paid to shareholders in owner-managed businesses
6. the start and end dates of self-employment

We welcomed responses from taxpayers, businesses, employers and other affected parties on all relevant options in the consultation. We included questions on the opportunities presented for improving tax administration and other services through use of the proposed data, the practical application of the proposed options for collecting data, and how we could minimise any administrative burdens.

Most respondents supported the purpose and policy rationale, but we received mixed views on some proposals with respondents emphasising that HMRC should make better use of existing data where possible and take account of the technical and practical challenges imposed. Chapter 3 sets out the detailed responses received for each proposal.

The government has listened carefully to the views expressed in the consultation and will look to take a measured and proportionate approach to collection of new data. The government intends to progress options where customers already hold the data, whilst keeping data collection requirements under review for other options where data is not already held or it would potentially add significant administrative burden to provide data in the format proposed. This means the government will be:

• publishing draft legislation for technical consultation in the coming months for inclusion in a future Finance Bill to enable data collection for employee hours worked via Real Time Information PAYE reporting, dividends paid to owner-managed businesses via the Self-Assessment return and start and end dates of self-employment as set out in the consultation

• keeping data collection under review for all other options set out in the consultation, including looking for alternative approaches to continue to improve the use of data already held. For example, information on business locations through Digitalising Business Rates, which the government consulted on in July 2022

As one of the largest data controllers in the UK, HMRC handles billions of records every year and has well-established systems and controls for safe and secure collection and the onward sharing of personal data in accordance with UK data protection legislation.

Further detail on the government response and next steps is set out in Chapter 4.

2. Introduction

Background to the consultation

Improving how HMRC collects, uses, and shares data continues to be a high priority for the department. This is a key element in building a trusted modern tax administration system fit for the challenges and opportunities of the 21st century, as set out in the government’s 10-year Tax Administration Strategy.

Reform of the current legislative framework, which is complex and inflexible, is critical to realising the full potential of a modern, digital tax system driven by efficient acquisition, matching and use of data (including from third parties) to enhance customer experience, reduce administrative burdens and reduce opportunities for errors and any potential non-compliance.

The government’s economic response to the coronavirus (COVID-19) pandemic was only made possible through the powerful use of data to make big policy decisions and deliver interventions, but it also highlighted areas where we could improve the data we hold about the citizens and businesses we serve.

This response document sets out how we are improving the data HMRC collects as part of the tax system, helping to make tax easier to get right and harder to get wrong.

In parallel, as part of the Tax Administration Framework Review, we are publishing a call for evidence exploring how we could reform HMRC’s information and data powers, to provide a cohesive, modern, and flexible approach to third-party data and streamline existing mechanisms for provision of better quality data to HMRC.

3. Responses

The government received 72 written responses from a broad range of affected businesses, tax professionals and other interested organisations. Annex A provides a list of respondents excluding individuals. As well as the written responses, HMRC held meetings and roundtables with businesses, agents, software and payroll service providers, including key professional bodies representing over 180,000 members.

The government is grateful to all those with whom the proposals were discussed and those who submitted responses, recognising the time and effort required. The responses and external discussions have helped the government to understand respondents’ views and concerns, as well as the potential impacts of the proposals.

The following sections set out the questions asked in the consultation and provide a summary of the responses to the overarching question and specific questions covering the 6 data options.

Overarching Question

The options consulted on were those assessed as bringing the greatest benefits when balanced against any additional administrative burden for customers. In addition to specific questions on each of the 6 options, the consultation asked an overarching question to understand whether taxpayers agree with the options prioritised.

Overarching question: across all of the options, we would like to understand which would be the most useful and would offer the most benefit for businesses and taxpayers. Do you think the options for collecting additional data we have prioritised here are the right ones, and are there any other areas where collecting more, better or different data would support tax administration and/or broader public service delivery?

There were very few responses to this question, with respondents preferring to provide feedback on the specific data options instead. The views expressed in these responses were split between those who welcomed the proposals and those who were concerned about the potential changes.

Sectoral data

Standard Industry Classification (SIC) of the main economic activity for a business tells us about its place in the economy and its prospects for the future. We identified self-employed sectoral data as having the biggest potential for improvement and set out 2 proposals to make the business description field compulsory, and/or to change the nature of business field from free text to SIC. As well as inviting views on the proposals, we were interested in understanding areas where data provided through different routes is, in practice, duplicative, and the challenges associated with the use of SIC codes.

The questions were:

Question 1: Within this option, should HMRC prioritise improving self-employed data as set out above, or another customer segment (for example, employers, companies, partnerships, businesses registered for VAT)?

Question 2: Are there any areas of the tax system where HMRC’s collection of sectoral data could be streamlined or where we could collect this information in a different way? In particular, does your business provide sectoral data to HMRC (or other parts of government) in more than 1 place (for example, to HMRC through both VAT and Self-Assessment; or to HMRC and to Companies House)?

Question 3 – for taxpayers and their agents: How easy or difficult are SIC codes to use for your business? What would make it easier for your business to find and input your SIC code(s)? What level of SIC would be most appropriate (for example, 3 or 4 digits)? Do you prefer using the full version from the Office for National Statistics, or the condensed version used by Companies House?

Question 4 – for software providers: How easy or difficult would it be for you to incorporate SIC codes into your software, in a way that is easy for your customers to use?

Summary of responses sectoral data

The majority of respondents agreed in principle with the proposal to prioritise the improvement of self-employed data. However, a number were sceptical, noting data quality concerns and increased administrative burdens, particularly on the self-employed. The main comments on sectoral data were grouped into the following themes:

• sectoral data is useful for the skills agenda and wider economic and labour market analysis – some respondents felt this data could enhance local authorities, researchers, and policymakers’ ability to fully assess what is happening in the sector and tailor policy development and support accordingly

• data quality and accuracy should be prioritised – most respondents accepted that SIC codes, if accurate, could result in more usable data. However, the complexity and burden of identifying relevant and accurate codes affects data quality and accuracy, and ultimately the analytical value of the resulting data. Several respondents suggested a degree of accuracy could be achieved by continuing to allow free text descriptions so taxpayers can accurately describe their sector without the limitations of predetermined codes, with an algorithm then converting this data into accurate SIC codes. Other respondents suggested developing and using a standard set of codes across government to ensure consistency and comparability, and ultimately reduce complexities and burdens

• administrative burdens should be minimised – many respondents felt the collection of this additional data risked increasing administrative burdens on the self-employed at a difficult time and for a customer group that already needs the most support in understanding its obligations. Out of the respondents that expressed a preference for a type or level of SIC codes, most generally preferred simplified and user-friendly codes, with the self-employed in particular expressing strong preference for Companies House’s condensed version of codes

• HMRC should use the data it already holds or has access to, in order to avoid duplication – to achieve this, a few respondents suggested that HMRC should improve the interoperability of its data and systems with other sources of information on sector. Some respondents identified areas where the collection of sectoral data is potentially duplicated or could be streamlined or collected in a different way. This includes sectoral data provided to Companies House and separately to HMRC, and data provided to HMRC in the contexts of VAT, Pay As You Earn (PAYE), and Self-Assessment tax returns

• technological capability was acknowledged by respondents to question 4 – the majority of these respondents were software and payroll service providers who agreed incorporating SIC codes into software would be achievable. However, they cautioned that the ease of implementation and use would depend on factors such as clear IT specifications, types of software, additional costs, and clear, detailed guidance

Government response for sectoral data

The government welcomes the general support for improving sectoral data and the potential this holds for improving tax administration and delivery of wider government policy. However, the government recognises the concerns raised by respondents of the complexity of identifying relevant and accurate SIC codes and the subsequent potential for adding additional administrative burdens for the self-employed.

As a result the government does not intend to take forward the proposed changes outlined in the consultation at this time. The government acknowledges the support from respondents for the benefits of improving sectoral data and will keep collection of sectoral data under review. The government will continue to explore options to simplify the collection of sectoral data and look for ways to improve sectoral data the government already holds.

Occupation data

Occupation data was outlined in the consultation as a useful tool for understanding the role of learning and skills towards economic growth. The proposal included in the consultation is to add a mandatory field to Real Time Information (RTI), the reporting mechanism for PAYE, requesting the occupation of each employee. For the self-employed, the proposal is to add a mandatory field to the self-employed supplementary Income Tax Self-Assessment forms (and the equivalent in Making Tax Digital for Self-Assessment), asking for ‘occupation or trade’, or similar wording. As well as inviting views on the specific proposals, we were interested in understanding other use cases for occupation data, and how easy or difficult the process of categorising occupations is.

The questions were:

Question 5: Would you find this information useful, if published in an anonymised form by the government (potentially linked with other datasets, such as salary, qualification, or location information)?

Question 6 – for employers/payroll providers: How easy or difficult would you find it to categorise each of your employees by occupation? If you have used Standard Occupational Classification (SOC) codes previously, how easy or difficult are they to use, and what, if any, challenges do you find with them? Do you have any suggestions as to how we could modify or design this option in a way that minimises cost burdens?

Question 7 – for the self-employed/their agents: How well do SOC codes describe your, or your clients’, occupation?

Question 8: How easy would it be to extract job titles from existing payroll systems into RTI?

Summary of responses occupation data

Respondents had mixed views on proposals to collect occupation data. A broad range of groups welcomed the proposal and the potential benefits occupation data could bring when linked with other datasets such as salary and qualifications. Views from business representatives were, however, split between those who supported the collection of occupation data and those who did not necessarily see the proposals’ direct benefits to business due to the complexity and burden of providing the data. The main themes from the responses included:

• data not for tax purposes – respondents expressed some concerns about HMRC overreaching their existing powers by collecting data that is not necessarily for tax administration purposes, and for onward use by other government departments. Some respondents felt HMRC should make it clearer that occupation as well as sectoral data, if collected, could be used for purposes other than tax administration. Linked to this was a challenge on how penalties could be applied fairly where errors do not necessarily affect tax liability

• transparency – another challenge highlighted was the ability for taxpayers to view and amend any incorrect data before it is relied on by other government departments. Several respondents also suggested that employees should have the right to challenge the employer’s role in collecting and providing this data to HMRC, or even opt out of the process altogether

• potential benefits and use cases – the majority of respondents to these questions, particularly those in the academic, policy, and skills areas and some representative bodies for small businesses and self-employed individuals, emphasised the usefulness of occupation data for research and analysis in areas such as labour market, skills, and social mobility. A specific example provided is where data could be used to make clear the link between qualifications and employment, which could support colleges in the design of their adult curriculum and the sequencing of qualifications that are likely to lead to employment

• data quality and accuracy – some respondents felt occupations and job titles are fast becoming outdated concepts which no longer largely describe the role an individual performs. Consequently, the resulting data may be misleading or too generalised even if it is combined with other datasets. Others were of the view that the lack of alignment across industries or sectors on job titles or occupation makes it difficult to achieve good quality data

• practical and technical challenges – several respondents highlighted complexities around accurately identifying and reporting occupations in different scenarios. For example, where employees hold more than 1 role in the same organisation, or where there are system issues which mean job title and occupation are not equivalents and not stored on the same system. This would then require businesses to devise and implement additional processes, resulting in administrative and cost burdens

Government response to occupation data

The government welcomes the general support for improving occupation data and the potential this holds for improving learning and skills outcomes and wider government policy delivery. However, the government also recognises similar issues to the concerns raised by respondents with identifying relevant and accurate SIC codes and the subsequent potential for adding additional administrative burden with this proposal.

As a result the government does not intend to take forward the proposed changes outlined in the consultation at this time but will keep collection of occupation data under review.

Location data

On location data we wanted to understand businesses with multiple locations, and where businesses’ real economic activity takes place. The proposal is to ask employers, through RTI, to give HMRC the office location or normal work base of their employees.

The questions were:

Question 9: Within location data, is HMRC correct to prioritise improving data on businesses with multiple locations, and on the location of real economic activity?

Question 10: Are there any areas of the tax system where HMRC’s collection of location data could be streamlined or where we could collect this information in a different way? In particular, does your business provide detailed location data (such as covering multiple branches of your business) to HMRC (or other parts of government) in more than 1 place? Which avenue do you find the least burdensome?

Question 11: How easy or difficult would it be for your business (or, for agents, your customers) to provide work location information for each employee through RTI?

Question 12 – for payroll providers: How easy or difficult would it be for you to modify your software/your service to allow for the provision of work location information for each employee?

Summary of responses location data

Although some respondents could see how location data would be useful in both HMRC and policy making contexts, there was broad consensus that the proposal as set out in the consultation would be challenging to achieve. Modern working practices such as home-working and hybrid-working, as well as the complexities around defining the location of businesses that operate from multiple locations, were some of the challenges repeatedly highlighted by respondents. The main themes from the responses included:

• mixed views on improving location data – respondents had mixed views on location data, with overwhelming support for improving this dataset from those who predominantly use the data for policy and research purposes. Most policy and research respondents tended to favour more granular data on location or other data options. All other respondents, particularly business representatives, felt that providing meaningful location data would be complex, costly, and administratively burdensome with no immediate tangible benefit to business

• challenges around defining and providing location data and data accuracy – some business respondents outlined their different circumstances which would make it difficult to provide an accurate and reliable location of where their real economic activity takes place. The most common complexities highlighted by most respondents were defining work locations in circumstances where employees are ordinarily mobile in the course of their work or where the employees have work locations that can change frequently. Examples provided were auditors, drivers, and those in the construction and contracting business who can work across the country or even all over the world, and where businesses have multiple locations

• suggestions of where the collection of location data could be streamlined – most respondents suggested obtaining business location information in a way that does not place additional burdens on businesses, for example, through local authorities’ licencing or business rates processes. Respondents felt the ongoing Digitalising Business Rates programme, which is expected to link business rates information to tax records, or the creation of dedicated Application Programme Interfaces (APIs) linking HMRC to various sources of business location data, would be better ways for HMRC to obtain data instead of adding to taxpayers’ reporting obligations. The same respondents however acknowledged this data might not satisfy all of the intended policy objectives but, on balance, would still be good enough from a cost-benefit perspective

Government response to location data

The government recognises the various challenges involved for employers of reporting location data to HMRC and welcomes the support for exploring ways to collect this data in a way which does not place additional burdens on business. The government sees the value in collecting location data but will not proceed with the approach set out in the consultation. The government will continue to explore alternative approaches to improve its understanding of business locations, including using information collected as part of Digitalising Business Rates.

Employee hours worked

The proposed approach is for HMRC to request, through RTI, numerical input of hours worked by employees (rather than hours in bands), and/or splitting out band e) (‘other’) on the return, to detail the reason for the irregularity of hours. HMRC sought views on how easy or difficult it would be for employers to use this approach.

The questions were:

Question 13: How easy or difficult would it be to provide information on specific hours worked and/or actual hours worked?

Question 14: How predictable are the hours of your employees? How often do you use category e) hours worked (‘no regular pattern’), and what for? For example, pension payments or irregular working patterns (and if so what type of irregular pattern)?

Summary of responses employee hours worked

Most respondents primarily focused on the challenges of providing actual hours worked by employees, and others provided general reflections on the overall proposed approach. A summary of the main comments and reflections is set out in the themes below:

• support for reporting actual hours for hourly rate employees and contractual hours for salaried employees – overall, there was broad consensus amongst respondents that it would be manageable for employers to identify actual hours worked by hourly rate employees and stable contractual hours for salaried employees. Most respondents believed employers should already hold detailed information on hours worked by employees paid by the hour as it is used to calculate wages. Respondents also felt that although hours worked by salaried employees would not be as readily available (as those for hourly rate employees), it would still be reasonably manageable to identify from existing records, stable contractual hours for salaried employees

• data quality and accuracy – most respondents felt the complexities around defining the boundaries of hours worked by employees would result in poor quality data which would not generate reliable insight needed for policy objectives. A key example cited by several respondents was the use of data for National Minimum Wage (NMW)/National Living Wage (NLW) monitoring. Although most respondents agreed with the principle of effectively monitoring and enforcing NMW/NLW, most did not believe that data on hours worked would enable identification of NLW/NMW non-compliance. Respondents acknowledged the risk that reported hours could always be manipulated, as recognised in the consultation, and used this and other factors to demonstrate the weaknesses of the proposed approach. Other complexities expected to result in poor data quality were around the validity and reporting of overtime, sick leave, irregular working patterns, travel time, and differing reporting periods in different organisations

• cost and administrative burden – most respondents in this section, and across all other data options, tended to highlight the intrinsic link between various complexities and cost and administrative burdens. On the proposal for hours worked by employees, respondents, particularly representatives of payroll and software providers, explained the need for software updates that enable the collection and reporting of the proposed data. Respondents highlighted that these updates and any other technical upgrades would be costly and administratively burdensome for business. Some software and payroll providers reflected that the expected benefit of this data did not outweigh the burden on business, particularly where the resulting data is expected to be inaccurate

• strong support by respondents specialising in policy and research, for more granular data in the form of numerical values (rather than bands) of hours that employees work – this group of respondents felt the information would be valuable for many use cases/purposes, including measuring income differences across groups, such as between genders, and for better understanding of macroeconomic questions such as productivity differences across regions, occupations, and industries, and slack in the labour market. Some respondents acknowledged that although survey data could be useful, it still falls short on the granularity and precision needed for proper analysis and evaluation of economic impacts

Government response for employee hours worked

The government welcomes the broad support for the principle of improving data on hours worked to help improve government support for the labour market. The government recognises the potential challenges raised by respondents for ensuring the accuracy of the data and is keen to take on board suggestions for requesting information that employers are more likely to hold.

Employers are already required to keep records of the hours their employees work to satisfy NLW and NMW rules, and in some cases display this information on payslips. Respondents also confirmed that employers will hold details of contractual hours worked for payroll purposes.

The government will therefore proceed with collecting improved data on employee hours worked. This will request information on contractual hours worked where those contractual hours are reasonably stable (such as not a zero hours contract) and actual hours worked for hourly rate employees, which will be proportionate and minimise additional burden. HMRC will work closely with businesses and software providers to ensure clear definitions and requirements and adequate time for implementation of changes. The government intends to share draft legislation for technical consultation on this change with affected businesses and organisations in the coming months before including in a future Finance Bill.

Dividends paid to shareholders in owner-managed businesses

The proposal seeks to build on the existing definition of a close company by asking directors to identify separately, on a mandatory basis, the amount of dividend income received from their companies on the SA102 (Employment page of the Income Tax Self-Assessment (ITSA) return), alongside their salary and benefits. We wanted to understand taxpayers’ views on the proposed approach, and the extent to which splitting out dividend income from controlled companies and/or determining the percentage of shareholding in that company would be burdensome.

The questions were:

Question 15: Do you agree that building on the pre-existing definition of a close company is the best approach? Are there any other approaches you would prefer?

Question 16: How great would the administrative burden be for you or your customers in splitting out dividend income from controlled companies and/or determining the percentage of shareholding in that company?

Summary of responses dividends paid to shareholders in owner-managed businesses

Overall, the majority of respondents supported the existing definition of close companies and felt building on this definition could add unnecessary complexity. Most respondents also felt that separate reporting of dividend income from close companies would be manageable and would not create any significant additional burden since the detail is already required as part of the aggregate reporting of dividend income. While most respondents largely endorsed the proposal, several shared general reflections and a few suggestions on how HMRC could collect this data. We have grouped these comments in the themes below:

• duplication – several respondents felt dividend information could be obtained from published accounts and Companies House records and should not have to be requested again through HMRC

• potential complexities – a few respondents cited complexities around the identification of shareholding. For example, where an individual’s percentage shareholding could change from year to year or within a year, through actions beyond their control. Or where there are different classes of shares or preference shares, resulting in confusion when viewed in conjunction with reported dividend income

• cost and administrative burdens – while the majority of respondents felt the proposals would not create any significant additional burden, some felt the extent of the burden would vary. The variation would be determined by the extent to which some of the complexities highlighted apply to those reporting their dividend income and percentage shareholding

• a few respondents suggested amending the SA100 return so that it requires specific reporting of dividends received from close companies – this could enable adjustments to the SA102 to be limited to the mandatory declaration of all directorships of close companies, including unremunerated ones, and confirmation if relevant, that the SA100 included the reporting of dividends from particular close companies

Government response for dividends paid to shareholders in owner-managed businesses

The government welcomes the broad support received from respondents for this proposal and the advantages improved data on the Company Owner Manager (COM) population could bring for targeting policy appropriately, including appropriate reliefs.

On the suggestion of using Companies House data, although dividend data is included in company accounts information, HMRC are unable to match this detail back to individual tax records.

With most respondents advising separate reporting of dividend income from close companies would be manageable and would not create significant additional burden, the government will proceed with the proposal outlined in the consultation for collecting additional data. This will request specific information on the SA102 form pertaining to the value of dividends and percentage shareholding in a close company of which the individual is a director.

The government recognises that COM ownership structures can be complex and HMRC will work closely with businesses and other affected parties to ensure clear definitions and requirements and adequate time for implementation of changes. The government intends to share draft legislation for technical consultation on this change with affected businesses and organisations in the coming months before including in a future Finance Bill.

Self-employed start and end dates

This proposal seeks to make completion of start and end dates fields mandatory within ITSA for the self-employed and the equivalent in Making Tax Digital for ITSA.

We asked the following question:

Question 17: How easy or difficult would it be for you/your clients to identify the dates that your business/your client’s business started and ended trading within a tax year?

Summary of responses self-employed start and end dates

Broadly, most respondents were supportive of the proposal but highlighted the need for HMRC to clearly define the scope of the proposed data to make it easier for taxpayers to provide accurate information. Respondents’ other general reflections and comments are summarised in the following key points:

• guidance – respondents felt guidance which clearly sets out the parameters of start and end dates would be essential to help taxpayers identify correct dates and clarify ambiguities of key definitions. For example, some respondents suggested it would be helpful for HMRC to set out the definition of ‘trading’ for the purposes of identifying start and end dates of self-employment, as this is not always straightforward. Guidance could help taxpayers deal with grey areas such as the transition between hobbies that become businesses. Or with circumstances caught by Trading Allowance rules which would mean reporting of profits from a new source could be required for the first time in a tax return without a trade having started in that year and, conversely, a reporting requirement ceasing without the source ending

• data quality – respondents felt that challenges associated with identifying start and end dates would influence the quality of data provided to HMRC

• penalties – respondents also felt that any penalties should be applied flexibly, recognising the challenges around identifying accurate and precise start and end dates

Government response for self-employed start and end dates

The government welcomes the broad support received from respondents for this proposal and the advantages improved data on trading activity can provide for targeting policy for the self-employed and partnerships.

The government will therefore proceed with plans for collection of this data as set out in the consultation. This will involve making mandatory completion of existing data fields on the Income Tax Self-Assessment and Partnership return (SA800).

The government recognises the need to clearly define the scope of the proposed data to make it easier for taxpayers to provide accurate information and HMRC will work closely with businesses and other affected parties to ensure clear definitions and requirements and adequate time for implementation of changes. The government intends to share draft legislation for technical consultation on this change with affected businesses and organisations in the coming months before including in a future Finance Bill.

4. Next Steps

This section summarises the next steps for each of the 6 data options outlined in the consultation.

Start and end dates of self-employment, dividends paid to shareholders in owner-managed businesses, and employee hours worked

The government will focus on options where data is already held by customers and will therefore proceed with collecting improved data on employee hours worked, dividends paid to shareholders in owner-managed businesses and self-employed start and end dates. The government intends to proceed with legislation and will share draft legislation with affected businesses and organisations in the coming months for technical consultation before including in a future Finance Bill.

HMRC will work closely with businesses and other affected parties to ensure clear definitions and requirements and adequate time for implementation of changes.

Sectoral, occupation and location data

While the government sees the value in collecting these data, it recognises the challenges and concerns raised by respondents with reporting them in the manner set out in the consultation, including the potential for additional administrative burdens for businesses and taxpayers.

As a result, the government does not intend to take forward the proposed changes outlined in the consultation at this time but will keep collection of data in these areas under review whilst continuing to look for ways to improve data the government already holds.

Annex A: List of respondents

The government is grateful to the 3 individuals and following organisations who responded to the consultation:

• The Association of Tax Technicians

• Federation of Small Businesses

• Institute of Directors

• The Association of Independent Professional and the Self-Employed

• The Institute of Chartered Accountants in England and Wales

• The Institute of Chartered Accountants of Scotland

• Chartered Institute of Taxation

• Chartered Accountants Ireland

• The Chartered Institute of Payroll Professionals

• Sage

• Norton Tax Shops Ltd

• Sibbalds Chartered Accountants

• Blue Mirror Insights Ltd

• Ernst & Young

• Synergy Accounts

• Integer Accounts

• Reddy Siddiqui Chartered Accountants and Business Advisors

• Torgersens Chartered Accountants

• The Careers and Enterprise Company

• World Skills UK

• Hull & East Yorkshire Local Enterprise Partnership

• Cornwall Council

• Devon County Council

• Association of Chartered Certified Accountants

• Essex County Council

• Low Pay Commission

• Low Incomes Tax Reform Group

• London School of Economics

• University College London

• KPMG

• Creative Industries Policy and Evidence Centre

• Social Mobility Commission

• Gatsby Charitable Foundation

• Greater London Authority

• Information Commissioner’s Office

• The Business Application Software Developers Association

• Workday

• Engineering Construction Industry Training Board (ECITB)

• Institute of Apprenticeships and Technical Education

• Falmouth University

• Nash Squared

• University of Warwick

• Engineering UK and the Royal Academy of Engineering