What Should I Do If I Receive a VAT Compliance Check
Received a VAT compliance check letter? This guide explains exactly what to do, what documents HMRC wants and how to reduce penalties during a VAT review.
As a chartered accountant running my own firm, I have supported many businesses through VAT compliance checks. The reaction is almost always the same at first, worry, stress, and the fear that something must be wrong. In reality, VAT compliance checks are a routine part of how HMRC monitor the VAT system. They are not automatically accusations of wrongdoing, and receiving one does not mean you have failed in your VAT obligations.
That said, how you respond to a VAT compliance check matters a great deal. A calm, organised, and informed response can make the difference between a straightforward review and a long, uncomfortable investigation. In this article, I want to explain exactly what you should do if you receive a VAT compliance check, what HMRC are usually looking for, how to prepare your response, and how to protect your business throughout the process.
This is written exactly as I advise my own clients, practical, realistic, and grounded in how HMRC actually operate in the real world.
First things first, do not panic
The most important advice I can give is this, do not panic.
HMRC carry out VAT compliance checks routinely. Many are random. Others are triggered by patterns such as repayment claims or changes in turnover. A compliance check is not the same as an accusation of fraud or deliberate wrongdoing.
Your goal at this stage is not to defend yourself emotionally, but to respond professionally and methodically.
Read the HMRC letter carefully
Before doing anything else, read the HMRC letter in full.
The letter will usually explain:
That HMRC are carrying out a VAT compliance check
Which VAT periods are being reviewed
Whether the check is desk based or involves a visit
What information HMRC are requesting
Deadlines for responding
Contact details for the HMRC officer
Understanding the scope of the check is critical. Do not assume HMRC are looking at everything unless the letter explicitly says so.
Identify what type of VAT compliance check it is
VAT compliance checks come in several forms.
The most common are:
Desk based checks conducted by letter or email
Aspect enquiries focusing on a specific area such as zero rating
Repayment checks following VAT refund claims
Full VAT inspections covering multiple periods
Remote checks using digital records
On site visits to your premises
Knowing which type you are dealing with helps you prepare appropriately.
Check the deadlines and diarise them
HMRC letters always include deadlines.
You should:
Note the response deadline immediately
Add reminders to your calendar
Allow time to gather information properly
Missing deadlines or responding late creates a poor first impression and can escalate the situation unnecessarily.
If you need more time, it is usually possible to ask, but this should be done early and politely.
Do not ignore the compliance check
Ignoring HMRC is one of the worst things you can do.
If you do not respond:
HMRC may issue estimated VAT assessments
Penalties and interest can follow
The check may escalate
HMRC may assume non cooperation
Even if you are unsure how to respond, acknowledge the letter and engage with the process.
Consider appointing an accountant or VAT adviser
If you are not already working with an accountant, this is often the point where professional support becomes invaluable.
An experienced VAT adviser can:
Deal with HMRC on your behalf
Review your VAT returns objectively
Identify risk areas early
Frame responses in the right language
Reduce stress and disruption
In my experience, involving an adviser early leads to far better outcomes than bringing one in after problems have escalated.
Authorise your adviser to speak to HMRC
If you do appoint an adviser, you will need to authorise them to act for you.
This allows HMRC to:
Communicate directly with your adviser
Request information through them
Discuss technical VAT issues professionally
Once authorised, it is usually best to let the adviser handle communications rather than responding personally.
Understand what HMRC are usually looking for
While every check is different, HMRC tend to focus on certain recurring areas.
Common focus points include:
Output VAT calculations
VAT rates applied to sales
Zero rated and exempt supplies
Input VAT claims
Entertainment and subsistence
Director expenses
Vehicle related VAT
Disbursements and recharges
Partial exemption
Flat Rate Scheme usage
Postponed VAT accounting
Consistency between VAT returns and accounts
Knowing this helps you prepare your records intelligently rather than reactively.
Gather the information HMRC have requested
HMRC will usually ask for specific documents.
These may include:
VAT returns for certain periods
Sales invoices
Purchase invoices
Bank statements
Accounting records
Contracts or agreements
VAT workings
Postponed VAT accounting statements
Partial exemption calculations
Provide exactly what is requested, no more and no less.
Over sharing can open up new lines of enquiry.
Review your VAT returns before sending anything
Before sending information to HMRC, review it yourself or with your adviser.
This review should look at:
Whether VAT returns match accounting records
Whether VAT rates have been applied correctly
Whether input VAT claims are supported by valid invoices
Whether any errors are apparent
Whether explanations are needed for unusual figures
Finding issues yourself is far better than having HMRC find them first.
Be honest about any mistakes
If you identify genuine errors, do not try to hide them.
HMRC treat mistakes very differently depending on behaviour.
Where errors are:
Careless
Acknowledged early
Corrected voluntarily
Penalties are usually much lower.
Trying to conceal mistakes almost always makes the situation worse.
Prepare clear explanations for unusual VAT positions
If your VAT returns include unusual features, be ready to explain them clearly.
Examples include:
Regular VAT repayments
Large input VAT claims
Sudden changes in turnover
New business activities
One off large purchases
Changes in VAT schemes
HMRC are far more comfortable when figures make sense and are well explained.
Keep communication professional and factual
All communication with HMRC should be:
Polite
Professional
Factual
Clear
Timely
Avoid emotional language, defensive responses, or speculation.
HMRC officers are trained to assess facts, not feelings.
Answer the questions asked, not every possible question
This is an important discipline.
When HMRC ask a question:
Answer that question directly
Provide supporting evidence
Do not volunteer unrelated information
Providing unnecessary detail can widen the scope of the check.
Keep copies of everything you send
You should keep copies of:
All documents sent to HMRC
All correspondence
Notes of phone calls
Dates and times of communication
This creates an audit trail and protects you if questions arise later.
Prepare for a visit if one is planned
If HMRC plan to visit your premises, preparation matters.
Before the visit:
Ensure records are organised and accessible
Ensure key staff are available
Agree the scope of the visit
Ensure your adviser is present if possible
You are entitled to have an adviser attend meetings with HMRC.
During an HMRC visit, stay in control
During a visit:
Answer questions honestly
Take time before answering complex questions
Refer technical issues to your adviser
Do not speculate
Do not guess figures
If you do not know an answer, it is perfectly acceptable to say you will come back with it.
Understand your rights during a compliance check
You have rights during a VAT compliance check.
These include the right to:
Understand why information is being requested
Ask for clarification
Request reasonable time to respond
Be treated fairly and professionally
Appeal assessments and penalties
Have representation
Knowing your rights helps you stay calm and confident.
What happens if HMRC find errors
If HMRC identify errors, several outcomes are possible.
These include:
No further action
Agreement to adjust VAT returns
Assessments for underpaid VAT
Interest charges
Penalties depending on behaviour
Not all errors lead to penalties, particularly where they are small and corrected promptly.
Penalties depend on behaviour
HMRC penalties depend heavily on behaviour.
They look at whether errors were:
Careless
Deliberate
Concealed
They also consider:
Whether you cooperated
Whether you disclosed errors voluntarily
How quickly issues were resolved
Good behaviour genuinely matters.
Time to Pay arrangements if VAT is due
If a compliance check results in VAT being payable and you cannot pay immediately, you may be able to arrange a Time to Pay agreement.
Early discussion with HMRC is key.
Time to Pay can:
Spread the cost
Reduce enforcement action
Allow the business to continue trading
Interest still applies, but penalties may be reduced.
Do not assume HMRC are always right
HMRC officers are human and can make mistakes.
If you disagree with HMRC conclusions:
Ask for explanations
Provide evidence
Challenge incorrect assumptions
Appeal formally if necessary
A professional adviser can be invaluable at this stage.
What to do after the compliance check ends
Once the check is complete, do not just move on.
You should:
Review any findings
Correct systems and processes
Update VAT procedures
Train staff if needed
Schedule regular VAT reviews
The goal is to reduce the risk of future checks.
Turn the experience into an improvement opportunity
In my experience, the businesses that benefit most from compliance checks are those that use them as a learning opportunity.
A VAT compliance check often highlights:
Weak bookkeeping
Poor VAT understanding
Lack of internal controls
Over reliance on assumptions
Fixing these issues strengthens the business long term.
Common mistakes I see during VAT compliance checks
From real world experience, the most common mistakes are:
Panicking and overreacting
Ignoring deadlines
Providing too much information
Trying to justify incorrect VAT treatment
Failing to involve an adviser
Treating HMRC as adversaries rather than regulators
Avoiding these mistakes makes the process far smoother.
Final thoughts from real world experience
Receiving a VAT compliance check is unsettling, but it does not have to be a disaster. In most cases, it is a routine review that can be handled calmly and professionally with the right preparation.
The key is to respond, not react. Read the letter carefully, understand what HMRC are asking, gather accurate information, and seek advice where needed. Cooperation, honesty, and organisation go a long way.
If there is one takeaway, it is this. VAT compliance checks are rarely about catching people out. They are about ensuring the system works. Businesses that understand that, and prepare accordingly, usually come through the process with minimal disruption and a stronger VAT position than before.