Appeals for Late Payment & Filings Virtual Service AssistsPractice admin for UK accountants
Menu
Book a consultation
Compliance and regulatory

HMRC penalty appeals for accounting practices, drafted with the evidence

When a client's penalty notice lands, the 30-day clock is already running. We build the timeline, gather the proof of a reasonable excuse and hand your team an appeal that is ready to approve and submit.

Book a consultation
The 30-day window

How an appeal moves from notice to submission

HMRC usually gives 30 days from the date of the penalty notice. Most of that time is lost waiting for the client to send evidence, so the chasing starts on the day the notice is logged.

Example schedule. Actual timing depends on how quickly the client provides evidence; the 30-day limit and later stages are set by HMRC.
WhenWhat happensWho
Day 0Date printed on the penalty notice. The 30 days run from here, whatever day the client opens the letter.HMRC
Day of loggingNotice logged with its deadline. We check the return has been filed and the tax paid, since HMRC only accepts an SA appeal once the return is in.VSA
First weekChronology built from portal records, emails and the client's account. Evidence requested: hospital letters, death certificate, IT fault logs, insurer reports, HMRC outage dates.VSA, with the client
Second weekAppeal drafted: the excuse, why it stopped the client meeting the deadline, and when the failure was put right. Evidence indexed and attached.VSA
Third weekYour team reviews, edits and approves, then submits online or on form SA370 signed as agent.Your practice
Day 30Usual deadline. A late appeal can still be accepted if you explain the reason for the extra delay.HMRC
After HMRC repliesIf HMRC does not change its decision, you have 30 days from the date of the offer to accept a review or appeal to the tax tribunal. We diarise it and prepare the file.Your practice decides

Sources: GOV.UK, Disagree with a tax decision or penalty; HMRC form SA370 (Self Assessment: appeal against penalties for late filing and late payment); GOV.UK, Self Assessment: how to appeal against penalties. HMRC's Self Assessment Manual (SAM10090) says that once an excuse ends, the return or payment should follow without unreasonable delay, and gives 14 days as a guide.

Penalty tables

What late filing and late payment cost your client

The amounts that most often reach a practice's inbox. Knowing which stage a penalty sits at tells you how much an appeal can save and whether more penalties are about to be added.

Self Assessment

Source: GOV.UK, Self Assessment tax returns: penalties. Applies to returns outside Making Tax Digital for Income Tax.
Late filingPenalty
1 day late£100
3 months late£10 a day, up to £900
6 months late5% of tax due or £300, whichever is greater
12 months lateAnother 5% or £300, whichever is greater
Interest is charged on top. Source: GOV.UK, Self Assessment tax returns: penalties.
Late paymentPenalty
30 days late5% of tax unpaid
6 months lateAnother 5% of tax unpaid
12 months lateAnother 5% of tax unpaid

Companies House accounts

Source: GOV.UK, Late filing penalties (Companies House). The penalty doubles if accounts are filed late in two successive financial years.
Time after the deadlinePrivate company or LLPPublic company
Up to 1 month£150£750
1 to 3 months£375£1,500
3 to 6 months£750£3,000
More than 6 months£1,500£7,500

Company Tax Return

Source: GOV.UK, Company Tax Returns: penalties for late filing. If the return is late 3 times in a row, the £200 penalties rise to £1,000 each.
Late filingPenalty
1 day late£200
3 months lateAnother £200
6 months late10% of unpaid tax, based on HMRC's estimate
12 months lateAnother 10% of unpaid tax

Clients in Making Tax Digital for Income Tax move to points-based late submission penalties and a different late payment regime. Source: GOV.UK, Penalties for Making Tax Digital for Income Tax.

Reasonable excuse

What HMRC accepts as a reasonable excuse, and the evidence behind it

A reasonable excuse is something that stopped the client meeting an obligation they took reasonable care to meet. HMRC judges each case on its facts, so the evidence carries most of the weight.

Example HMRC may acceptEvidence we gather
A partner or close relative died shortly before the deadlineDeath certificate or funeral notice, with dates set against the filing deadline
An unexpected hospital stay, or a serious or life-threatening illnessAdmission and discharge letters, GP or consultant letter covering the period
Computer or software failure while preparing the online returnSoftware support tickets, error screenshots, repair invoices with dates
Problems with HMRC online servicesPortal error records, HMRC service availability notices, call logs
Fire, flood or theft that prevented the return being completedInsurer report, crime reference number, photographs
Postal delays that could not have been predictedProof of posting, tracking history, Royal Mail disruption notices
Delays related to a disability or mental health conditionMedical or support worker evidence explaining the effect at the time
Relying on someone else to send the return, who failed to do soEngagement records and the steps the client took to check the return had gone

What HMRC says it will not accept

  • A cheque bounced or payment failed because there was not enough money
  • The client found HMRC's online system too difficult to use
  • The client did not get a reminder from HMRC
  • A mistake on the tax return

Companies House is stricter

The registrar's discretion is very limited. Appeals usually fail if they rest only on the company being dormant, being unable to pay, relying on an accountant, accountant illness, first-time filing, directors being abroad or postal delays. They can succeed where an unforeseen event happened at a critical time close to the deadline, or Companies House made an error.

Sources: GOV.UK, Tax appeals: reasonable excuses; GOV.UK, Late filing penalties (Companies House); GOV.UK, Appeal a penalty for filing your company accounts late. For a longer walkthrough, read Appealing HMRC late filing and late payment penalties: a practical guide for UK practices.

Agent routes

Which route for which penalty

Each regime has its own form, its own preconditions and its own next step if the first appeal fails. We prepare the appeal in the format the route needs.

PenaltyHow the appeal goes inBefore you appealIf it is refused
Self Assessment late filing or paymentOnline, or form SA370 (SA371 for partnerships) within 30 days of the notice date. SA370 can be signed by an agent.Send the return and pay the taxOffer of review; 30 days to accept it or go to tribunal
Company Tax Return late filingAs set out on the penalty noticeFile the Company Tax Return firstReview or tribunal, 30 days from the offer
VAT penaltiesHMRC offers a review in the penalty letter; for penalties from January 2023 it can be accepted in the VAT online accountCheck which submission or payment triggered the penalty and that it has now been made30 days to accept the review or appeal to tribunal
Companies House late filingOnline appeal service or email, with company number, penalty reference, reason and supporting documents. One appeal per penalty notice.Deliver the accountsSenior Casework Unit, then the Independent Adjudicators

Sources: GOV.UK, Disagree with a tax decision or penalty; GOV.UK, Company Tax Returns: penalties for late filing; GOV.UK, Appeal a penalty for filing your company accounts late; GOV.UK, Late filing penalties. GOV.UK also notes that if the penalty is not paid and the appeal fails, interest runs from the date it was due, so your practice may advise the client to pay while the appeal is decided.

Who does what

We draft. Your practice signs and submits.

An appeal is a statement made on your client's behalf, so your team approves every word before it reaches HMRC or Companies House.

We handle

  • Logging each notice with its date, reference and 30-day deadline
  • Checking filing and payment status in the agent portal
  • Building the chronology and requesting evidence from the client
  • Drafting the appeal and the SA370 or covering letter
  • Tracking HMRC's reply and diarising review deadlines

Your practice keeps

  • Deciding whether an appeal has merit
  • Advising the client on paying the penalty in the meantime
  • Approving and submitting under your agent authorisation
  • Any decision on statutory review or tribunal
Questions

HMRC penalty appeals: common questions

What counts as a reasonable excuse for HMRC?

Something that stopped the taxpayer meeting an obligation they took reasonable care to meet. GOV.UK examples include a close relative's death shortly before the deadline, an unexpected hospital stay, software failure, HMRC online service problems, fire, flood or theft, and unforeseeable postal delays. Lack of money, finding the system difficult, no reminder and mistakes on the return are not accepted.

How long do you have to appeal an HMRC penalty?

Usually 30 days from the date the penalty was issued, which is the date on the notice. If you miss it, HMRC can still accept a late appeal if you explain the reason for the extra delay. For Self Assessment, the return must be filed before HMRC will accept the appeal.

Can an agent appeal a penalty on a client's behalf?

Yes. Form SA370 asks anyone signing for someone else to state the capacity, such as agent. Practices also appeal through the routes on each penalty notice. We prepare the appeal and evidence; your practice approves it and submits it under its own authorisation.

Can you appeal a Companies House late filing penalty?

Yes, once per penalty notice, online or by email, with the company number, penalty reference, reason and supporting documents. Success is rare: the registrar only has discretion for exceptional, unforeseen events close to the deadline, such as serious illness or a fire destroying records, or a Companies House error.

What is the difference between a late filing and a late payment penalty?

A late filing penalty is charged because the return arrived after the deadline, even if no tax is owed. A late payment penalty is a percentage of tax that stayed unpaid at set points, 30 days, 6 months and 12 months for Self Assessment. Both can be appealed with a reasonable excuse, often together.

Does relying on the accountant count as a reasonable excuse?

For HMRC it can, where the client relied on someone else to send the return and they did not, though HMRC will look at what the client did to check. Companies House treats reliance on an accountant as a reason that is unlikely to succeed on its own.

What happens if HMRC rejects the appeal?

For direct taxes, HMRC offers a review. You then have 30 days from the date of the offer to accept the review or appeal to the tax tribunal. We diarise that date and prepare the file, and your practice decides which route to take.

Related services

HMRC and Companies House portal admin

Deadline diaries and daily notice checks, so filings go in before penalties start.

SA100, CT600 and CGT support

Return preparation support through the January peak. Read our guide to surviving Self Assessment season.

Client inquiry support

First-line replies when a worried client forwards a penalty letter.

Got a penalty notice on the desk now?

Send us the notice date and we will tell you what evidence the appeal needs and how quickly the draft can be with you.

Book a consultation