Impact assessment

SA100 postal output project screening equality impact assessment

Published 7 September 2023

Project objectives

For the tax year 2022 to 2023, we will stop automatically sending paper Income Tax Returns to approximately 135,000 taxpayers who have previously filed their returns by paper. Instead, those taxpayers will receive a letter advising them of the change, encouraging them to file their returns online, with guidance on how to do so for the first time.

For those who can’t go digital, the letter will include a number to call HMRC and ask for a paper return to be sent out if needed.

These customers should then also receive a ‘notice to file’ (SA316) in April asking them to file online by the deadline, sent to all Self Assessment customers. The initial letter provides context and further support ahead of this notice to file.

Customer groups affected

The customer groups that will be impacted by the change are Self Assessment customers including:

• paper filers
• paper filers with reasonable adjustments
• VIMU paper filers
• Welsh language paper filers
• under 70s
• 16 to 24 year-olds

What customers will need to do

What customers need to do as a result of the change

Self assessment customers are being encouraged to file online. Customers who wish to file by paper will need to contact HMRC to request a paper form using the phone number provided in the advisory letter or using details provided on GOV.UK.

How customers will access this service

Customers can access the Self Assessment online form or call HMRC for a paper form. If going online, they need Government Gateway authorisation.

Access to Government Gateway could be more difficult for customers who may have difficulties providing the correct documentation due to race, migrant status, age or disability. This is a known impact for some customers who are directed to use HMRC and government digital service.

Customers finding online access or authorisation difficult, or who wish to file by paper, can contact HMRC to request a paper form using the phone number provided in the advisory letter or using details provided on GOV.UK.

When customers need to do this

Customers will need to complete their online Self Assessment by 31 January 2024.

Customers who choose to file by paper will need to complete their paper Self Assessment by 31 October 2023.

Assessing the impact

We assessed the impact on those in protected characteristic groups in line with the Equality Act and Public Sector Equality Duty and section 75 of the Northern Ireland Act: racial groups, sex, gender reassignment, sexual orientation, pregnancy and maternity, marriage and civil partnership, people with dependants and those without (carers), political opinion (in Northern Ireland only).

There is no evidence to suggest any specific impacts on those customers within any of the protected characteristic groups listed above. Extra support will be provided as required, and a non-digital option is provided.

Impacts on the following groups have been identified.

Disabled

Impact on customers

Evidence suggested that no longer automatically sending a SA100 paper form to those who have previously filed a paper Self Assessment return and encouraging them to file online may impact disproportionately on disabled customers as evidence suggests these customers are less digitally capable.

This may include impacts on customers with learning disabilities, mental health conditions, neurodivergence conditions, fine motor skill difficulties and vision problems.

It is acknowledged that the wording on the letters is to strongly encourage those to file online if they can. This may increase anxiety for some customers which may exacerbate existing mental health conditions.

We will continue to issue a paper form to customers who have an existing reasonable adjustment for an alternative format of the SA100.

HMRC has been able to identify customers who require an alternative format, such as those who are visually impaired and have met these requirements.

There may be some impact on customers who are not able to use the telephone to order a paper form. This may be due to a hearing or speech impediment.

Proposed mitigation

For those who are unable to complete the form digitally a paper copy can be requested via the order telephone line. Contact details for the order line will be given to customers in the advisory letter and on GOV.UK.

We will continue to issue a paper form to customers who have an existing reasonable adjustment for an alternative format of the SA100.

Customers can complete the SA100 digitally if they can successfully access Government Gateway.

Customers can authorise an agent help them complete the Self Assessment digital return if they are unable to complete the online form themselves. A 64-8 needs to be completed if the customer nominates an accountant, tax agent or tax adviser to deal with Self Assessment submission.

Where a customer cannot call the helpline for any reason, friends or family or a representative from a voluntary community sector (VCS) organisation can order a form on their behalf.

The SA100 will be available to view on GOV.UK. This will aid the VCS organisation when providing support to customers.

In the SA316 (notice to file) we will signpost customers to the Self Assessment GOV.UK pages where it will explain how to order a paper form using the telephone and how to access extra support services.

Order line call handlers will refer customers to Extra Support Team services if they require additional support.

Details of how to access the extra support service are available on GOV.UK via the order form page and ‘Self Assessment: general enquiries’ page.

Age

Impact on customers

Evidence suggested that to stop sending a SA100 paper form and encouraging customers to digitally file could impact disproportionately on older customers as evidence suggests that these customers are less digitally capable.

Younger customers may have difficulties accessing HMRC and Government Gateway due to a lack of verifiable documentation, including National Insurance number.

Proposed mitigation

Customers can complete the SA100 digitally if they can successfully access Government Gateway.

We will continue to issue paper forms to customers who are over 70 and have not filed online before.

Customers can authorise an agent to help them complete the Self Assessment digital return if they are unable to complete the online form themselves. A 64-8 needs to be completed if the customer nominates an accountant, tax agent or tax adviser to deal with Self Assessment submission.

For those who are unable to complete their return online, a paper copy can be requested via the order telephone line. Contact details for the order line will be given to customers in the advisory letter which will be issued for customers with no previous Self Assessment online filing history.

Where a customer cannot call the helpline for any reason, friends or family or a representative from a VCS organisation order a form on behalf of the customers.

The SA100 will be available to view on GOV.UK. This will aid the VCS organisation when providing support to customers.

In the SA316 we will signpost customers to the Self Assessment GOV.UK pages where it will explain how to order a paper form using the telephone and how to access extra support services.

Order line call handlers will refer customers to Extra Support Team services if the customer requires additional support.

Details of how to access the extra support service are available on GOV.UK via the order form page and ‘Self Assessment: general enquiries’ page.

Religion or belief

Impact on customers

Some customers due to religious reasons may not be able to engage digitally.

Proposed mitigation

For those who are unable to complete the form digitally a paper copy can be requested via the order telephone line. Contact details for the order line will be given to customers in the advisory letter which will be issued for customers with no historical Self Assessment online filing history.

Where a customer cannot call the helpline for any reason, friends or family or a representative from a VCS organisation order a form on behalf of the customers.

The SA100 will be available on GOV.UK to view only. This will aid the VCS organisation when providing support to customers.

In the SA316 we will signpost customers to the Self Assessment GOV.UK pages where it will explain how to order a paper form using telephone and how to access extra support services.

We will continue to issue paper forms to Ministers of Religion.

People who use different languages (including Welsh language and British Sign Language)

Impact on customers

There may be some impact on deaf customers and customers with language barriers who may not be able to use the telephone to order a paper form.

Proposed mitigation

The order line is compatible with Relay UK services.

In the SA316 we will signpost customers to the Self Assessment GOV.UK pages where it will explain how to order a paper form using telephone and how to access extra support services.

The Extra Support Team can arrange for customers to be supported by British Sign Language interpretation services if requested.

Call handlers can access ‘Big Word’ interpretations services to support a customer if needed.

Welsh language Self Assessment customers will be provided with Welsh language versions of the letters.

Opportunities to promote equalities

We have considered opportunities to promote equalities and good relations between people in each of the protected characteristic groups and those outside of that group.

External stakeholder engagement:

• engaging with other government departments and stakeholders to inform them of the changes and highlight support
• articles in MP and stakeholder digests, asking for these to be shared with their networks
• media briefing to ensure the changes are understood, and where support can be found
• voluntary and community sector engagement to inform them of the changes and highlight support
• presented at the Additional Needs Working Group and the Individual Stakeholder Forum to discuss the changes and gather feedback

A full equality impact assessment is not recommended.