Why has HMRC delayed my VAT refund?

HMRC delays a VAT refund when it opens a repayment verification check under section 25 VATA 1994. It reviews evidence behind your input tax before paying out. Most checks resolve within weeks, but complex claims, new registrations or large repayments can take longer. You cannot force early payment while the check is open.

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Do this first

Read HMRC's letter carefully and note the exact documents requested.

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
Section 25 and section 73 Value Added Tax Act 1994
Applies to
Any VAT return showing a repayment due to you
Typical timescale
HMRC aims to process most repayments within 30 days of the return, longer if it opens a check
Records HMRC can request
Invoices and evidence required under Schedule 11 VATA 1994
Appeal route
Complain first, then appeal to the First-tier Tribunal under section 83 if HMRC refuses to pay

The short answer, explained

HMRC has stopped your repayment because it wants to check the figures before releasing money. This is a repayment verification check, not an accusation of wrongdoing.

It happens routinely, especially for new VAT registrations, unusually large claims, or returns with a pattern that differs from your normal trading. HMRC is entitled to satisfy itself the input tax you're claiming is genuine and correctly evidenced.

The delay itself doesn't mean you've done anything wrong. It means an officer wants to see the paperwork behind the numbers before signing off the payment.

The rule behind it

Section 25 VATA 1994 sets out how input tax is credited and repaid. Section 73 gives HMRC power to assess if it isn't satisfied a return is complete or accurate. Together, these let HMRC hold back a repayment while it checks the underlying evidence.

Schedule 11 VATA 1994 gives HMRC the right to require production of records, invoices and accounts to support a return. If you can't produce satisfactory evidence for a claim, HMRC can reduce or refuse it.

There's no fixed statutory deadline for how long a verification check must take. HMRC's own guidance sets an indicative target for straightforward repayments, but that target doesn't apply once a check is opened.

What this means for a limited company director

Cash flow is usually the immediate worry. A delayed refund can be a meaningful sum for a limited company, particularly if you've built a return around expecting it.

You should expect HMRC to write asking for specific invoices, contracts or bank statements. Respond promptly and completely: incomplete responses are the single biggest cause of checks dragging on longer than necessary.

If your company relies on VAT repayments as a normal part of its cycle, for example if you're zero-rated or heavily export, build the possibility of a check into your cash flow planning rather than assuming refunds arrive on schedule.

What this costs you

There's no direct penalty for being subject to a verification check. The cost is the lost use of your own money while the refund sits with HMRC, plus the time your team spends gathering evidence.

If HMRC ultimately reduces the claim, it may raise an assessment for the difference, with interest running from the date the reduced amount would have fallen due.

Growth plan clients get free tax investigation insurance included, which covers professional costs if a repayment check escalates into a wider enquiry. See /fees for what's included at each level.

Common mistakes to avoid

Don't ignore HMRC's request for information hoping the payment will arrive anyway; it won't, and delay only lengthens the check.

Don't submit invoices that don't match the description of the supply on your return. Mismatches are a common trigger for extending a check.

Don't assume every request is unreasonable. Read exactly what's being asked for and provide it in the format requested, rather than sending a bulk data dump that takes longer to review.

What to do next

  1. Read HMRC's letter carefully and note the exact documents requested.
  2. Gather invoices, contracts and bank evidence that match your return figures.
  3. Respond within the timescale given, even if only partially ready, and explain any gaps.
  4. Ask your accountant to review the claim before you send anything to HMRC.
  5. If the delay becomes unreasonable, raise a formal complaint through HMRC's complaints process.

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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