ECSH47130 - Notifying changes

If at any point on or after registration, it is identified that a business has failed to notify HMRC of a material change or provided inaccurate information, you should determine when the material change occurred or if the inaccuracy has already been brought to the business’ attention.

As detailed in Regulation 57(4) of Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLR 2017):

  • Businesses have 30 days to report a material change to HMRC. This deadline to report a change is reduced to 14 days if a business changes its Nominated Officer or Compliance Officer under Regulation 21(4) of MLR 2017.
  • Businesses have 30 days to correct an inaccuracy.
  • HMRC may agree to extend the deadline to report a change or correct a inaccuracy beyond 30 days.

If you identify a material change that has not been reported or an inaccuracy that needs corrected, you should contact the business to:

  • Have the change reported.
  • Correct the inaccuracy.

Material changes that occurred less than 30 days ago

If you identify a material change that occurred less than 30 days ago, you should advise the business to amend its registration to report the change by the 30 day deadline. E.g. The business appoints a director on 2 November 2024 and has until the 1 December 2024 to notify HMRC of this change.

Material changes that occurred more than 30 days ago

It may be the case that you identify a material change that occurred more than 30 days ago. In this instance you should advise the business to amend its registration to report the change. You may consider applying a type 3 penalty as the business has failed to notify HMRC of a material change within 30 days.

Inaccuracies that have previously been brought to the business' attention 

If you discover an inaccuracy that a business has previously been brought to the business’ attention which has not been corrected in 30 days, you should consider applying a type 3 penalty.

Reporting a change of sector

A business is unable to report a change of sector whilst its application is outstanding. If you require a business to report a change of sector, you should follow the guidance in ECSH45854.

Establishing the reason for the failure

You should consider writing out to the business to establish the reason that it did not notify HMRC of the change when it occurred or did not correct the inaccuracy within 30 days of the inaccuracy being brought to its attention. Once the business has responded, you will need to determine whether the information provided is false or misleading and consider what sanction is appropriate.  See ECSH81075.

No action taken by deadline: new applications

If the change or inaccuracy has not been updated on the registration or rectified by the deadline, the business’ application should be refused. If you identify a risk of Money Laundering, Terrorist Financing or Proliferation Financing (MLTFPF) or you have established that the information was false or misleading you should consider if further sanctions may be appropriate.

No action taken by deadline: existing registrations

If the change or inaccuracy has not been reported or rectified by the deadline, you should consider issuing a Type 3 Penalty to the business and consider applying further sanctions if you identify a risk of MLTFPF or you have established that the information was false or misleading.