Why so little care from HMRC for Vulnerable Customers?

We have some vulnerable customers. We take them seriously. So much so that in the last year we have developed a ‘vulnerable customer policy‘, and now all Covertax team members have undergone enhanced DBS checks.

Why bother?

Well our view is that just like you wouldn’t put your friends and relatives in the care of someone who has not been checked, we feel that the same should be expected of professional advisers.
In some of our cases we do develop a close working relationship. We are relied upon. And we wish our clients and their advisers to be sure that they are in safe hands. Hence going that step further.

And what about HMRC?

Whilst the Government seeks to protect vulnerable customers, there is no consistent vulnerable customers policy within HMRC or indeed the Tribunal Service. We know this because we have asked in respect of our own vulnerable customers. And we accept that either the respondents correctly reported a lack of vulnerable customers policy for all their customers, or else were living in ignorance of their policy, which in some respects is worse and would indicate a serious training need within HMRC. Indeed, we feel that there is a serious training need in any event.

HMRC makes no effort in normal circumstances to identify a vulnerable customer, or indeed agent, upon first contact.
The nearest we have to an HMRC policy is some isolated comment in respect of Direct Recovery of Debts (“DRD”), whereby HMRC can help themselves to the contents of the person’s bank account. Our understanding is that this policy arose because of pressure upon the Government to ensure that DRD did not disadvantage vulnerable customers. We have not seen this extended to other vulnerable customers within HMRC’s Debt Management regime, HMRC’s general contact with its “customers” nor within the appeals process either within HMRC or the Tribunal.

Direct Recovery of Debts

As regards DRD, HMRC says “Those who are identified as vulnerable will not be considered for DRD, and will be given alternative support to help them pay the money they owe.” Briefly, this means that HMRC will take the money in any event, but not by raiding the person’s bank account.

From what we have seen, there seems little regard to the challenges vulnerable people face. For example, we have live cases where the vulnerable person has received penalties instead of help – the worst example of this is a dyslexic HMRC customer served complex notices.
HMRC has, however, set out indicators for identifying vulnerable customers, but only in respect of DRD:

Indicator A – a disability or long-term health condition

For example, a disability, mental health condition or learning difficulty that directly impacts on debtors’ ability to communicate with HMRC or to manage their HMRC affairs, meaning they are unable to understand or appreciate their indebtedness. The effects of the disability or condition may be temporary or long-term in nature.

Indicator B – a temporary illness, physical or mental health condition

For example, diagnosed with a serious illness or condition that affects them to such an extent that they are unable to understand or appreciate their indebtedness or to put their HMRC affairs in order.

Indicator C – personal issues

Issue that affect them to such an extent that they could not understand or cope by themselves.

For example:

  • becoming recently widowed
  • a family bereavement
  • being made redundant
  • a serious illness
  • caring issues
  • trauma caused by an assault
  • domestic or financial abuse

These may be issues that affect [the taxpayer] directly or someone close to them (such as an immediate family member).

Indicator D – lower levels of literacy, numeracy and/or education

For example, learning difficulties that mean they are unable to fully understand their indebtedness without advice or support.”


It is our view that both HMRC and the Tribunal’s Service should have a vulnerable customers policy for all aspects of their work. This is something we will campaign for through our various professional bodies, as well as in direct contact with HMRC.
We would encourage other professional firms to follow our lead, both in respect of their own customers, but also in respect of contact with their professional bodies and contact with HMRC.

Steve Botham