Does HMRC have to tell me why they're investigating me?

HMRC must tell you the general area under review, such as the tax year, tax type, or specific figures being checked, so you can respond properly. It does not have to reveal every internal reason a check was opened, including specific risk indicators or whether it followed a tip-off, since that would undermine future compliance work.

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Do this first

Read the opening letter to identify the tax, year, and any specific area mentioned.

If the reply date on your letter is within 14 days, call 020 3441 1258 rather than waiting, or check the reply to an enquiry you have already sent.

Key facts

Statutory basis
Taxes Management Act 1970, section 9A (self assessment enquiries) and Schedule 36 Finance Act 2008
What's disclosed
The general subject of the check, for example the year, tax, or figures in question
What's withheld
Internal risk-scoring detail and the source of any tip-off or informant
Random checks
HMRC can open enquiries without any specific trigger at all
Appeal route
There's no appeal against the level of detail given, only against formal decisions made during the check

What level of explanation am I entitled to?

When HMRC opens a compliance check, whether under section 9A Taxes Management Act 1970 for self assessment or through a Schedule 36 notice, it should identify the tax, the period, and broadly the area of concern. This lets you understand what records and explanations are relevant without HMRC having to justify its suspicion in detail.

In practice, opening letters often say something like 'we are checking your Self Assessment tax return for the tax year ended 5 April 2024' or refer to a specific entry, such as rental income or a particular expense category. That's usually the extent of what's provided upfront.

Why doesn't HMRC have to explain its full reasoning?

HMRC's risk-assessment methods, including the data-matching tools and third-party information sources it uses, are deliberately not disclosed case by case. If HMRC revealed exactly what triggered every check, it would become far easier for people to structure their affairs to avoid detection rather than to comply properly.

This is consistent with how most regulatory and law enforcement bodies operate: the target of a check is entitled to know what's being examined, not the internal methodology that led to the examination.

Can HMRC open a check with no specific reason at all?

Yes. HMRC can open a self assessment enquiry into any return within the statutory enquiry window without needing a specific suspicion, and some checks genuinely are selected at random or through general risk profiling rather than a targeted concern. You cannot infer wrongdoing is suspected simply because a check has started.

If your enquiry is random, cooperating promptly and providing clear, well-organised records is usually the quickest way through it, since there's no underlying issue to uncover.

What if I think the real reason hasn't been disclosed?

It's common to suspect a check was prompted by something specific, such as a mismatch with third-party data or a tip-off, even where the opening letter is generic. Asking HMRC directly what prompted the check rarely gets a fuller answer, but asking what specific figures or entries it's focused on often does.

A more productive approach than pressing for the 'real reason' is to ask HMRC to confirm, in writing, exactly which entries or years are within scope, so you know what to focus your response on.

Does the level of disclosure change as the check progresses?

Yes. As a check develops, HMRC generally becomes more specific about what it's querying, particularly once it raises formal questions about individual transactions or issues a closure notice setting out its conclusions. The initial letter is deliberately broad; later correspondence should narrow considerably.

If HMRC reaches a formal decision, such as an amendment or assessment, it must give reasons for that decision, and those reasons can then be tested on appeal to the First-tier Tribunal.

What to do next

  1. Read the opening letter to identify the tax, year, and any specific area mentioned.
  2. If the letter is vague, write asking HMRC to confirm precisely what entries or figures are under review.
  3. Don't assume a lack of detail means wrongdoing is suspected; many checks are risk-based or random.
  4. Focus your response on the areas HMRC has identified rather than volunteering unrelated information.
  5. Ask an accountant to review the letter if you're unsure what it's actually asking about.

Where we can help

Sources

About the author

Waqas Sagar ACA FCCA FMAAT, Managing Director. 18+ years advising UK directors on HMRC enquiries, supported by a team with over 100 years' combined experience.

Reviewed: 16 September 2026 · Next review: 16 March 2027

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