After Tonight’s Close: Third-Party Data Prep Toward April 2028

HMRC’s technical consultation “Draft legislation: Better use of new and improved third-party data” closes at 11:59pm on 20 August 2026. After midnight, the structured response window ends — but the measure’s planned force date remains 6 April 2028. Tonight’s close shapes draft secondary legislation under Schedule 23 Finance Act 2026, schemas for interest income and card sales, and due-diligence notices; it is not the go-live date for ongoing data feeds.

From April 2028, in-scope data holders would provide data on an ongoing basis without a fresh HMRC notice, report to set frequencies, collect and verify customer tax references, make reasonable efforts to obtain missing data, and notify HMRC before reporting. Sole traders and limited companies that take card payments or earn bank interest are not the primary consultation audience, yet they sit on the receiving end of sharper matching.

Watch GOV.UK for HMRC’s response summary and any revised draft regulations — silence does not mean the draft is frozen.

Keep programme plans for tax-reference collection, due diligence, and notification workflows on an April 2028 runway, separate from Finance Bill draft-clause work closing 7 September.

Industry bodies that filed tonight should diary follow-up meetings rather than assuming schemas will ship unchanged.

Reconcile merchant settlements to sales ledgers monthly so card-sales feeds will not surface unexplained gaps in 2028.

Keep interest certificates and bank interest postings aligned to the same entity and accounting period — richer third-party interest data will make mismatches harder to explain away.

Ask your adviser how customer tax references may be requested by banks or acquirers once the rules harden; do not wait until 2028 onboarding letters arrive.

Treat Making Tax Digital quarterly updates and clean digital records as complementary discipline — third-party feeds and digital books will increasingly tell the same story.

Clean sales and interest books make third-party matching less painful once richer feeds arrive. FinnAccountings helps Ireland and UK sole traders and limited companies prepare bookkeeping and tax packs with Chartered Accountant insight before you or your ICAEW/ACCA or Chartered Accountant (Ireland) adviser files. We prepare review-ready drafts — we do not file consultation responses or HMRC data-gathering returns for you.

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This morning’s closing-night briefing still holds the final-hours checklist.

Third-party data closes tonight — 20 August →

Keep Finance Bill draft-clause themes on the September runway.

Finance Bill draft clauses: 18 days to 7 September →

MTD sign-up outage prep belongs on the same digital-records track.

MTD sign-up outage: three weeks to 11 September →