Is my HMRC enquiry random or targeted?

Most HMRC enquiries are risk-based, triggered by data-matching, inconsistent figures or industry comparisons through HMRC's Connect system. A smaller proportion are genuinely random, used to sample compliance across the population. The opening letter rarely states which category applies, so treat every enquiry the same way procedurally.

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Do this first

Read the enquiry letter closely for any specific figures or years 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 power
Section 9A, Taxes Management Act 1970, covers both random and risk-based enquiries equally
Main risk tool
HMRC's Connect system, matching returns against third-party data sources
Random enquiries
A smaller fixed proportion, used to check general compliance levels and validate risk models
Practical effect
Your rights and obligations are identical whether the enquiry is random or targeted
Appeal route
No appeal against opening; challenge arises at the closure notice or assessment stage

The short answer, explained

There is no public marker on an enquiry letter telling you whether HMRC selected your return because of a specific risk flag or purely at random. In practice, the large majority of enquiries follow some form of risk indicator, since HMRC's resources are targeted where a discrepancy is more likely.

A genuinely random sample is still used, partly to catch non-compliance that risk models miss, and partly to keep those models accurate by comparing outcomes across risk-flagged and random cases.

The rule behind it

Section 9A of the Taxes Management Act 1970 gives HMRC a broad power to enquire into any return within the time limit, without distinguishing between random and risk-based selection in the legislation itself. Both routes carry exactly the same statutory process once the enquiry is open.

HMRC's Connect system draws together data from banks, Land Registry, letting agents, online marketplaces, payment processors and international information exchange under the Common Reporting Standard. It flags mismatches between what HMRC already knows and what a return declares, which drives most risk-based selection.

Because HMRC does not have to give reasons for opening an enquiry, and there is no appeal against the decision to open one, it is rarely worth spending much effort trying to establish which category your case falls into. Your obligations to respond and provide accurate information are the same either way.

What this means for a limited company director

If HMRC's enquiry letter references specific figures, such as a particular expense category, dividend level or property income, that strongly suggests a risk-based trigger rather than a random check. General requests for full records across the board can indicate either.

Directors should keep company and personal records consistent regardless, since a risk-based Connect flag on one side of the personal/company split often leads HMRC to ask about the other.

What this costs you

Whether random or targeted, the enquiry itself has no fee attached. Costs arise from professional time spent responding, and from any additional tax, interest or penalty if HMRC identifies an error.

Tax investigation insurance included with our Growth plans covers professional costs of managing the enquiry through to closure — see /fees.

Common mistakes to avoid

Do not assume a general-looking letter means the enquiry is random and therefore low risk. HMRC sometimes frames risk-based enquiries broadly to see what else comes to light.

Avoid contacting HMRC to ask directly whether the enquiry is random, since officers are not required to answer and it rarely changes how you should respond.

Do not treat a random enquiry casually. HMRC still applies the same penalty rules if it finds an error, regardless of how the case was originally selected.

What to do next

  1. Read the enquiry letter closely for any specific figures or years mentioned.
  2. Gather full supporting records regardless of whether the enquiry appears targeted or general.
  3. Respond fully and accurately to every point raised within the deadline given.
  4. Seek professional support early if the scope of the enquiry is unclear or widens.

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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