Official Statistics

Non-domestic rating: challenges and changes Background Information

Published 2 February 2023

1. Scope and content of the data

This release contains statistics relating to Challenges and Changes for England and Wales across the 2017 rating list. Statistics on the 2017 rating list for England include checks and challenges under the new Check, Challenge, Appeal (CCA) process. Further information is provided below, and more information on the CCA system can be found in the CCA section.

1.1 Checks, Challenges and Changes against the 2017 local rating list for England

This publication captures registrations, property claims, checks and challenges made from April 2017. Registrations and property claims are presented at national level to comply with VOA’s statistical disclosure policy on ensuring published data remain confidential.

These tables include:

Statistics related to cases raised under the CCA process (for the 2017 rating list), including:

• Table 1.1: Summary of Checks and Challenges over the lifetime of the list
• Table 1.2: Registrations for CCA by month: interested persons (IPs) and agents
• Table 1.3: Approved property claims for CCA by month
• Tables 2.1 to 2.2: Checks and Challenges registered, resolved and incomplete by month
• Table 2.3: Checks and Challenges outstanding at the end of each month
• Tables 2.4 and 2.6: Summary of Checks and Challenges by administrative area over the lifetime of the list
• Tables 2.5 and 2.7: Outcomes of resolved Checks and Challenges over the lifetime of the list
• Table 3.1: Change in rateable value for resolved Checks, Challenges and Appeals
• Table 3.2: Change in rateable value for resolved Checks, Challenges and Appeals by financial quarter

Statistics relating to the assessment reviews raised against the 2017 rating list including:

• Tables 4.1 to 4.2: Assessment reviews (reports) received and resolved by administrative area and financial quarter
• Table 4.3: Assessment reviews (reports) outstanding by administrative area at the end of each financial quarter

1.2 Challenges and Changes against the 2017 local rating list for Wales

In Wales, challenges against the 2017 local rating list are handled using the same process as the 2010 local rating list for England and Wales. Statistics on the 2017 local rating list for Wales include:

• Tables 1.1 to 1.2: Challenges received and resolved by administrative area and financial quarter
• Table 1.3: Challenges outstanding by administrative area at the end of each financial quarter
• Table 2.1: Breakdown of all formal Challenges resolved throughout the life of the list
• Tables 3.1 to 3.2: Assessment reviews (reports) received and resolved by administrative area and financial quarter
• Table 3.3: Assessment reviews (reports) outstanding by administrative area at the end of each financial quarter

2. Differences between CCA Statistics and Non-CCA Statistics

The statistics in this publication can be broadly grouped into two types, CCA-process related statistics (2017 rating list checks and challenges in England) and non-CCA-process related statistics (statistics on challenges and reviews, the 2017 rating list for Wales and the 2010 rating list for both England and Wales). It is important to understand the differences between the two sets of statistics.

2.1 Definition of a challenge

A challenge has a different and specific meaning when used in the CCA process as opposed to when used under the non-CCA process:

• CCA process – a challenge to a valuation is made only after the completion of a check
• Non-CCA process – a challenge can be either a proposal to change a valuation or a subsequent appeal against a valuation

This is covered in more detail in the Glossary.

2.2 Registered and received

CCA check and challenge statistics show the number of checks and challenges registered by the VOA while non-CCA challenge statistics show numbers of cases received by the VOA as at a point in time. When information is received by the VOA manually it is marked with a ‘received’ date. The information is then registered on the VOA administrative system at which point a ‘received’ and ‘registered’ date are recorded.

2.3 Change in Rateable Value for resolved Checks, Challenges and Appeals (Table 3.1 and 3.2)

The Covid-19 pandemic can be attributable to increases seen in some of the monthly data from March-20. As table 3.1 for the England 2017 list is cumulative, these increases are not obviously clear. Table 3.2 breaks the checks, challenges, and appeals down by quarter for England level only.

3. Check, Challenge, Appeal

The business rates appeal process in England from 1 April 2017 is known as Check, Challenge, Appeal (CCA). The VOA deals with checks and challenges, while the independent Valuation Tribunal for England (VTE) handles appeals. This service applies to England only. Business rates appeals are handled differently in Wales, Scotland and Northern Ireland.

Owners, occupiers, and authorised agents must first register to use the online service and view or request details of their valuation.

There are three stages to the new process – ‘Check’, ‘Challenge’ and ‘Appeal’:

• The Check stage sets out exactly how a valuation has been calculated. It provides the Interested Person (IP) with all the underlying facts and allows them to update those facts if they have changed or are incorrect. This means that everyone understands and agrees the factual basis for any valuation, and that valuation can be amended at this stage if necessary.
• The Challenge stage allows people to challenge the valuation if they feel the calculation done based on the facts established at Check is incorrect. IPs or their agents provide the full evidence for their challenge, giving the VOA the opportunity to resolve the issue without the need for an Appeal. The VOA are required to present the full evidence to support their decision.
• If IPs are not satisfied with the VOA’s decision, having understood all the evidence and basis for the decision, they can appeal to the independent VTE. This appeal is undertaken in the full knowledge of all the evidence and arguments put forward from both sides at the Challenge stage.

Figure 1 provides an overview of the CCA process:

Figure 1

As well as counts on checks and challenges received, these statistics also contain number of registrations and property claims under the new CCA process. The Valuation Tribunal Service publish their own statistics on appeals. Further information about CCA can be found on GOV.UK.

4. Technical Notes

This release includes statistics on challenges made by taxpayers (or their representatives) against the 2017 local rating list. It also includes statistics on reviews of rating assessments (known as reports) that have either been initiated by the VOA or a billing authority, when new information becomes available. Previous quarters’ figures include retrospective changes so will not necessarily be the same as those from previous publications.

Figures in the release note may be rounded to a different level of accuracy from the figures in the MS Excel tables and should therefore be considered more definitive.

The statistics are derived from VOA’s administrative database and are published at national, regional, and billing authority level.

The VOA is required, by the Local Government Finance Act 1988, to compile and maintain accurate rating lists specifying a rateable value for all non-domestic rateable properties in England and Wales. These rateable values provide the basis for national non-domestic rates bills, which are issued by billing authorities. There is a local rating list for each billing authority. However, for simplicity, we have referred to these throughout this publication as one combined ‘rating list’ for those local lists effective from 1 April 2010, and, likewise, one combined ‘rating list’ for those local rating lists effective from 1 April 2017.

Ratepayers, owners, and in limited circumstances, relevant authorities, and other persons (known formally as Interested Persons) can make a challenge to alter the rating list if they think an entry is incorrect. Challenges can also be made on behalf of interested persons by their professional representatives.

The process for challenging the rating list currently differs between England and Wales. In Wales a challenge, known as a proposal, is made to the Valuation Officer asking them to change the entry in the rating list. After a period of discussion if the Valuation Officer cannot reach agreement with the ratepayer the matter will then be referred to the Valuation Tribunal Service, at which stage it becomes an appeal. In England a new three stage appeals system was introduced in 2017, called Check, Challenge, Appeal (CCA).

5. Data Quality

5.1 Suitable data sources

The information supplied in the tables is based upon administrative data held within the VOA’s operational database. All administrative data are subject to processing and process errors and as such, while the VOA has made every effort to ensure accuracy of the data underpinning this publication, it is possible that some errors remain.

5.2 Assured quality

Our quality assurance follows the approach set out in the VOA Quality Policy.

As part of the production of this publication, quality assurance takes place:

• during the valuation of properties
• as part of the creation of the data which underpins the publication
• as part of the coding which produces the publication outputs
• as part of automated and manual checks of outputs
• using a comprehensive QA Check List and a QA Issues Log

6. Use made of the data

This publication is being released as part of a drive towards making the VOA’s data more accessible as well as continuing to improve, and make more consistent, presentation of information to assist users conducting their own analysis of VOA data. The data are used to inform government policy and conduct analyses to support the operations of the VOA.

In a wider context this publication supports BAs’ requirements for information in respect of the Business Rates Retention Scheme contained within the Local Government Finance Act 2012.

We will keep under review the format of this summary document to improve the presentation of our statistics and welcome feedback from users on the usefulness of the information provided in this summary. Please forward any comments to the VOA statistics team.

7. CSV Metadata

A file which provides the variable names and descriptions appearing in the CSV files is included in this release; it can be found within the ‘CSV Files’ zip file on the release page.

8. Timeliness and Punctuality

Timeliness refers to the lapse of time between publication and the period to which the data refer. Punctuality refers to the gap between planned and actual publication dates.

Releases are always punctual and published on the pre-announced dates. Pre-announcement of the precise date may occur up to four weeks before publication. We always pre-announce the month of publication in our 12-month planning schedule.

This publication is published on a quarterly basis within two months of the last day of the reference period.

9. Relevance

Relevance is the degree to which statistical outputs meet users’ needs.

It is important that the statistics produced are relevant to user needs and that they meet the needs of users, both in coverage and in content. These statistics evolved largely in response to Freedom of Information requests and Parliamentary Questions and were further developed with input from a NDR Statistics Advisory Panel which consisted of key users of the data.

10. Coherence and Comparability

Coherence is the degree to which data that are derived from different sources or methods, but refer to the same topic, are similar. Comparability is the degree to which data can be compared over time and domain, for example, geographic level.

These statistics are drawn from the same source and use a coherent and consistent methodology.

CCA and non-CCA statistics cannot be compared as these statistics relate to different processes. For further information, please see the ‘Differences between CCA statistics and non-CCA statistics’ section of this document.

11. Accessibility and Clarity

Accessibility is the ease with which users can access the data, also reflecting the format in which the data are available and the availability of supporting information. Clarity refers to the quality and sufficiency of the release details and accompanying advice.

The release is available free of charge. All official statistics are made available primarily as Excel spreadsheets with data available in an open format (CSV versions) and a background information document.

12. Confidentiality, Transparency and Security

Access to the data and release during its publication is limited to the statistics production team only. Occasionally, valuation experts may be consulted as part of the quality assurance process. The list of pre-release recipients is published alongside the release.

Further information can found within the VOA Confidentiality and Access policy.

13. Further Information

Timings of future releases are regularly placed on the Agency’s website in the upcoming releases section.

For further information on the area codes used in this release, please refer to the ONS Administrative Geography Guidance.

14. Glossary

Appeal (non-CCA process) – an appeal consists of both Valuation Tribunal cases and Upper/Lands Tribunals cases. A challenge only becomes an appeal when the proposal (IPP) is referred to the Valuation Tribunal Service.

Appeal (CCA process) – an appeal in the Check, Challenge, Appeal process consists of an appeal referred by the IP to the VTE for an independent review.

Area code– a unique identifier for administrative geographies as specified by the Office for National Statistics (ONS).

Assessment – an entry in the rating list is often referred to as an assessment.

Assessment review (report) – assessment reviews (reports) relate to instances where the VOA will review the entry in the rating list. They can be either a report initiated by the BA, known as a Billing Authority Report, or initiated by the VOA, known as a Valuation Office Report. These could typically be attributable to a demolition, new property build or other physical change to a property. An assessment review (report) is counted as received when it has been registered on the VOA’s administrative system.

Billing authority (BA) – a local authority empowered to collect non-domestic rates on behalf of itself and other local authorities in its area. In England, shires, metropolitan districts, the Council of the Isles of Scilly, unitary authorities, London boroughs and the City of London are BAs.

Billing authority code – a unique identifier for BAs.

Billing authority report (BAR) – a report (assessment review) initiated by the BA. These could typically be attributable to a demolition, new property build or other physical change to a property.

Cancelled challenge or assessment review (non-CCA process) – a challenge/assessment review raised against a property in error that is cancelled.

Central rating list – the VOA’s list of rateable values for companies named in the Central Rating List Regulations, primarily for the network property of major transport, utility, and telecommunications undertakings and cross-country pipelines. There are separate lists for England and Wales.

Challenge (CCA process) – the IP can challenge any valuation related to the same property within four months of the check completion. IPs can also make a challenge if the VOA has not completed the check after 12 months. If the challenge is about a change in the surrounding area (a material change of circumstances), then the challenge can be made either within four months after the check completion or within 16 months of the IP’s check confirmation.

Challenge (non-CCA process) – a proposal by the ratepayer to alter the 2017 rating list in Wales: typically attributable to a challenge to the assessed rateable value or a change of circumstance of the property as well as physical changes in the locality. Challenges consist of both IPPs and appeals. IPPs are commonly, though incorrectly, referred to as appeals; technically a challenge only becomes an appeal when the proposal is referred to the Valuation Tribunal Service. A challenge is counted as being received when it has been registered on the VOA’s administrative system. It is counted as being resolved when it has been cleared and the rating list has been updated.

Challenge outcomes (CCA process) – resolved challenges may be:

• Agreed – this category is made up of challenges resolved with an outcome of well-founded or agreement reached. Well-founded is an outcome where the VOA agrees with the proposed alteration to the list and the date from which the proposed alteration should take effect. Agreement reached is an outcome where the VOA and the IP come to an agreement which is different to the proposed alteration of the list and/or the date from which the proposed alteration should take effect.
• Disagreed – this category is made up of challenges resolved with a considered decision, which is where the VOA and the IP cannot agree the proposal, so the VOA issues its decision that may or may not result in an alteration to the list.

Check (CCA process) – a review by the IP of the information held by the VOA for their property. The IP confirms the accuracy of the facts on which the rating list entry is based, provides missing factual information and amends property details as necessary.

Check completion – a resolved check: the VOA have responded to the IP, stating the outcome in full and cleared the case.

Check confirmation – the point during check at which the IP confirms the accuracy of the facts on which the rating list entry is based, provides missing factual information and amends property details as necessary.

Check outcomes – there are three outcomes for resolved checks, which are:

• Agreed – the VOA agrees with/accepts all the facts provided by the IP. This can include checks that lead to no change to the facts proposed by the IP.
• Partially agreed – the VOA agrees with/accepts some of the facts provided by the IP.
• Disagreed – the VOA does not agree with/accept the facts provided by the IP.

Compiled list – the rating list as it comes into effect following revaluation; for the 2010 rating list this is the list as at 1 April 2010 and for the 2017 rating list it is the list as at 1 April 2017.

Direction – the Tribunal’s written instructions that the appellant and the VOA must follow.

Incomplete challenge – the challenge does not contain all the detail required in legislation and so is not accepted by the VOA.

Interested person (IP) – an interested person can be an individual or a company who is the owner, occupier or ratepayer of the property, or a person with a ‘qualifying connection’. A person has a qualifying connection if they own the company that owns the property, if they are a company owned by the property owner or occupier, or if both they and the property owner or occupier are companies owned by the same company.

Interested person proposal (IPP) (non-CCA process) – a proposal by the IP or agent acting on their behalf to alter the local rating list entry.

Invalid proposal (non-CCA process) – a proposal that has been submitted to the VOA that the VOA considers to be incorrect. In these circumstances the VOA informs the maker of the proposal why they consider the proposal to be invalid. The maker of the proposal has the option to appeal to the Valuation Tribunal against the VOA’s decision.

Lands Tribunal cases – the functions of the Lands Tribunal were transferred to the Upper Tribunal (Lands Chamber) on 1st June 2009. These cases are now known as Upper Tribunal cases and includes any appeal to the Upper Tribunal (Lands Chamber), Court of Appeal and Supreme Court.

Local rating list(s) – the VOA’s lists of all the non-domestic rateable properties in England and Wales. There is a separate local list for each BA.

Minor rating list change (MRL) – a minor change to a rating list entry usually correcting a typographical error in the address or description of a property.

Outstanding – a case is counted as being outstanding when it has been registered on the VOA’s administrative system and has not been resolved.

Property claim – before anyone can access more detailed valuation data about a property, they must prove that they have a legal interest in the property under the non-domestic rating legislation, for example as an owner or occupier or both. To do this, they are required to ‘claim their property’ through the VOA’s online service and provide proof of their relationship to the property, such as a copy of a business rates or utility bill. Once the VOA confirm the interested person’s relationship to the property, the claim is approved, and the IP can view or request the detailed valuation for that property. Note that the figures of approved property claims may be adjusted in future publications to reflect where claims have been updated.

Rateable value (RV) – a monetary value assigned to every rateable property within a rating list, broadly based on the annual rent for which a rateable property could have been let on the open market at a set date.

Ratepayer – the person required to pay the business rates bill for the property. This is usually the occupier unless the property is empty when it is the owner’s responsibility to pay.

Received – a case is counted as being received when it has been received by the VOA.

Region – a geographical unit formerly referred to as Government Office Region (GOR). The GOR framework was the primary classification for regional statistics and comprised nine regions of England, which, combined with the devolved administrations, collectively spanned the United Kingdom. From 1 April 2011 the term GOR was dropped in favour of region. This release comprises English regions and Wales.

Registered – a case is counted as being registered when it has been registered on the VOA’s administrative system. Note this may differ from the date the case was sent to the VOA.

Resolved challenge – a challenge will be resolved when it has been cleared on the VOA’s administrative system. This will be because it has either been agreed (well founded), a negotiated agreement has been reached (agreement reached), it has been withdrawn, or the VOA have disagreed with the challenge and issued a decision notice (considered decision).

Resolved check – the VOA have completed the check, stating the outcome in full and cleared the case.

Struck out – the decision made by the Valuation Tribunal not to hear an appeal and give it no further consideration. This is usually because of a failure of the appellant to comply with a direction of the tribunal.

Unique rateable property (also known as hereditament) – a unit of non-domestic property that is, or may become, liable to non-domestic rating and thus appears in the local rating list. The area of a property included in a rateable value calculation can cover all of one property, only part of a property or be several separate units in one building or site.

Upper Tribunal (Lands Chamber) – this was previously known as the Lands Tribunal before its functions were transferred to the Upper Tribunal on 1 June 2009. This is a specialist tribunal that resolves certain disputes concerning land, particularly the valuation of land. It has power to hear cases under many different Acts of Parliament and statutory instruments.

Valuation Office notice (VON) – the notice of alteration to the rating list that arises when the VOA amends a rating list following either a BAR, a Valuation Office report (VOR) or settlement of an IPP.

Valuation Office report (VOR) – a report (assessment review) initiated by the VOA to review an entry in the local rating list. These could typically be attributable to a demolition, new property build or other physical change to a property.

Valuation officer – an employee of the VOA and the officer authorised by statute to compile and maintain rating lists.

Valuation Tribunal (VT) – an independent appeals tribunal, to handle council tax and rating appeals in England (VTE) with a similar but separate Valuation Tribunal in Wales (VTW).

Withdrawn – the IP withdraws their proposal.