HMRC Information Powers & Digital Records Reform: Comment by 7 September 2026

On Legislation Day (13 July 2026), HMRC published draft Finance Bill 2026–27 clauses and a tax information note reforming civil information and inspection powers under Schedule 36 to the Finance Act 2008, and modernising the computer-records definitions in section 114 of the same Act. Technical consultation on the draft closes on 7 September 2026 — comments go to [email protected].

The package does not invent a brand-new information power. It updates how existing Schedule 36 notices work in a digital economy: cryptoasset and related payment providers come into Financial Institution Notice (FIN) scope, identification notices can request more unique identifiers, time limits for notices after a taxpayer’s death are extended (with tribunal or authorised-officer safeguards), and s114 is rewritten so “documents” clearly cover software, automated calculations, and cloud-held records.

Financial Institution Notices will extend to businesses that provide services relating to cryptoassets and to payment service providers that facilitate payments connected with those services. HMRC’s impact note expects hundreds of entities to need familiarisation; many larger platforms already respond to third-party notices, but FIN process rules and timelines will need operational playbooks.

Identification notices will still need authorised-officer approval, but any HMRC officer may issue them. Identifying information that can be requested expands beyond traditional identifiers to include items such as National Insurance number and email address — only where the recipient holds them.

For software providers and cloud bookkeeping platforms, the s114 updates clarify that where HMRC already has a lawful Schedule 36 basis, a notice can require relevant digital information needed to understand how tax figures were produced — including outputs from automated processes. Existing safeguards remain: information must be reasonably required to check a tax position or collect a debt. HMRC says approaches to examining commercial taxation software will continue to start on a voluntary basis.

Today, an information notice to check the tax position of a person who has died generally cannot be issued more than four years after death. The draft extends that window, subject to tribunal approval for most notice types (authorised-officer approval for FINs). HMRC frames this as aligning the UK with OECD exchange-of-information standards so overseas requests can still be met.

The statutory requirement to produce an annual Parliamentary FIN report under section 126 of the Finance Act 2021 will be repealed. HMRC states it will continue to publish FIN usage data for transparency. Operative date for the package is Royal Assent to Finance Bill 2026–27.

Map who holds your tax-relevant data: in-house ERP, cloud bookkeeping, payroll bureaux, crypto or payment platforms, and advisers. Confirm retention, export formats, and how automated VAT or income-tax workings are logged so you can evidence calculations if a notice lands.

If you operate a cryptoasset or payments business, review FIN response procedures and legal hold playbooks now — do not wait for Royal Assent. Software vendors serving UK taxpayers should track the consultation and be ready to explain calculation provenance without oversharing intellectual property.

Keep working papers and digital ledgers organised for review. FinnAccountings helps UK and Ireland businesses centralise bookkeeping and tax prep drafts with Chartered Accountant insight before you or your ICAEW/ACCA adviser responds to compliance checks — start a free trial to build an auditable digital pack. Pair this briefing with our Finance Bill 2026–27 Legislation Day overview and the free tax calculator for planning estimates only.

For other L-Day administration themes, see our securities transfer tax Finance Bill note and the Pillar Two Side-by-Side draft legislation update. Sole traders already in Making Tax Digital should keep quarterly digital records tight ahead of the 7 August 2026 first update deadline.