HMRC Third-Party Data Consultation Closes 20 August 2026
HMRC’s technical consultation on draft legislation for better interest and card-sales data closes at 11:59pm on 20 August 2026 — eleven days for banks, merchant acquirers, and industry bodies to respond before April 2028 rules lock in.
HMRC’s technical consultation “Draft legislation: Better use of new and improved third-party data” closes at 11:59pm on 20 August 2026. The pack covers draft secondary legislation under Schedule 23 Finance Act 2026, draft schemas for interest income and card sales data, and draft notices on due diligence and data-holder notification.
The policy aim is familiar: help customers get tax right first time by improving how HMRC matches third-party feeds to taxpayer records, supporting digital prompts, and targeting compliance interventions more accurately. From 6 April 2028, in-scope data-holders must report on an ongoing basis without waiting for a notice.
What the draft rules would require from April 2028
In-scope organisations — including banks, building societies and other financial institutions, merchant acquirers, and payment facilitators — would need to provide data to a set frequency and deadline, collect and verify specific tax references from customers before submission, make reasonable efforts to obtain missing required data, and notify HMRC before reporting.
Draft schemas would replace the existing BBSI and other interest data schemas for interest income, with a separate card-sales schema for merchant acquiring data. Responses go by email to [email protected] — say whether you are a business, individual, or representative body, and for representative bodies how many people you represent.
This consultation is technical. It is aimed mainly at data-holders and industry bodies, not at every sole trader rewriting their 2026/27 return this week. Still, card-taking SMEs and anyone with material bank interest should understand what will feed HMRC’s matching engines from 2028.
Why SMEs and landlords should care now
Tighter interest and card-sales matching means unexplained gaps between merchant settlements, bank interest certificates, and declared income become harder to shrug off later. Use the consultation close as a prompt to tidy sales channel maps: card terminals, online gateways, marketplace payouts, and cash — each needs a clear path into your digital books.
Landlords and sole traders already inside Making Tax Digital for Income Tax should keep interest and property income categories consistent across quarterly updates and year-end. Soft landing on late quarterly-update points in 2026/27 does not soften third-party data matching once the 2028 regime is live.
If you advise banks, acquirers, or payment facilitators, treat the next eleven days as the last structured chance to flag schema field problems, due-diligence friction, or notification timing before secondary legislation hardens.
Practical checklist before 20 August
Data-holders and trade bodies: read the draft regulations, schemas, and due-diligence notice; respond with concrete operational examples rather than general support or opposition.
Card-heavy SMEs: reconcile July and early-August merchant statements to sales ledgers now, and keep customer-facing invoices aligned with settlement batches.
Individuals with large interest pots: keep certificates and account schedules export-ready so your adviser can explain totals when pre-population and nudges expand.
How FinnAccountings helps keep sales and interest explainable
Clean sales and bank categories make third-party matches easier to evidence. FinnAccountings helps Ireland and UK businesses prepare bookkeeping and tax packs with Chartered Accountant insight before you or your ICAEW/ACCA or Chartered Accountant (Ireland) adviser reviews figures. Start a free trial for review-ready drafts — we prepare packs; we do not respond to HMRC consultations or file returns on your behalf.
Related reading
See our earlier third-party data briefing for the full April 2028 policy context, then the MTD landlord catch-up guide if property income still sits outside digital records. Use the free tax calculator only for high-level Income Tax and National Insurance planning.
Landlords still catching up after the 7 August MTD deadline should keep rental and interest categories tidy before later matching tightens.
Open the dual-market tax calculator for planning estimates only — not for modelling HMRC data schemas.
Sources & references
This article draws on official guidance and publications from the sources below.
- 1.Draft legislation: Better use of new and improved third-party data
HM Revenue & Customs · Accessed 2026-08-09
- 2.Draft legislation (accessible version)
HM Revenue & Customs · Accessed 2026-08-09
- 3.Better use of new and improved third-party data to make it easier to pay tax right first time
HM Revenue & Customs · Accessed 2026-08-09
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