If I were on the HMRC board

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Wendy Bradley reviews how complaints about HMRC are resolved and how she would change the system if she was in charge.

Starting point

The HMRC complaints process begins with a complaint to the area of the organisation about which the taxpayer is complaining. This allows low level misunderstandings to be cleared up relatively quickly and easily. In the jargon, this allows the relevant staff to "consume your own smoke".

There is now a facility to make this kind of complaint via an online form although you have to faff about signing in via a government gateway account in order to use it.


The fear, for a complainant, is that the person who made the initial error or caused the initial offence will simply double down and repeat it, so it is important that there is a second-tier to the complaints process. This is where HMRC can make the most use of complaints to find hotspots requiring attention and to track wider trends.


According to HMRC’s 2017/18 Annual Report, the department received 77,410 new complaints in that year and resolved "around 99%" internally, although it does not specify how many were resolved in the first tier and how many progressed to tier two.

The second tier is described simply thus: "If you disagree with the outcome of your complaint you can ask HMRC to look at your complaint a second time. A different customer service adviser [my emphasis] will review your complaint and give you a final response."

Why this is important

If I were on the HMRC Board, this is the area I would explore in considerably more detail. As HMRC staff are now concentrated in larger offices with fewer staff career moves, this lack of mobility may encourage a local canteen culture to develop.

I would track the second-tier complaints to be sure that there were no rogue areas within HMRC who are forming their own customs and practices.

Complaints should be valuable feedback on where things are going well and where less well. Conversely, an area with no complaints at all would, surely, be inherently suspicious.

A second "customer service adviser" isn't quite the same thing as a separate cadre of complaints handlers empowered to look across the piece and, were I on the HMRC Board, I'd be looking for the latter.

The adjudicator’s role

After the second customer service adviser gives a formal closure letter, the complainant may then go to the independent adjudicator's office. 

However, to get there, not only does the taxpayer have to jump through the hoops of getting the HMRC complaints process settled, the complainant can't even email the evidence to the adjudicator. A cynic may think the complainant was being discouraged from pursuit.

Why no email?

The ability to email the adjudicator with a complaint about HMRC used to be possible. Here is the page on Direct.gov, captured in 2007 with an email address for taxpayers to send complaints via, amongst other channels, "e-mail at [email protected]".

But now the current page tells us we can write, telephone or fax, but the adjudicator is "unable to accept complaints or enquiries by e-mail".

The adjudicator's office business plan contains the answer: HMRC won't give them the funds to move their website to gov.uk and to set up a secure email system. The adjudicator’s office admits that this lack of email and website “is a barrier to customers who want to complain, and disadvantages our customers.”

Is the adjudicator independent?

The adjudicator is independent of HMRC but the service level agreement between the adjudicator's office (AO) and HMRC includes these points:

  • HMRC will provide funding to cover agreed operational costs and provide relevant performance data for forecasting purposes.
  • In keeping with HMRC’s commitment to continuous improvement, the AO will seek to improve business performance in service delivery and value for money.
  • The staff in the AO are HMRC employees.

You may ask why HMRC should be funding and staffing an organisation that listens to complaints about them, but in fact this is excellent practice.

Aside from an irreducible minimum of unjustified complaints that every organisation receives, the complaints an organisation receives are actually a valuable source of data and can spur process improvement.

Digital divide

How does HMRC square its ambition to be the leading digital tax authority with its refusal to fund its complaints handling service to become fully digital? I asked HMRC and a spokesperson replied:

“We treat complaints seriously, and seek to resolve them quickly within our own internal complaints process so that customers don’t have to take their complaint to the Adjudicator.”

He continued: “Our focus is to learn lessons from all customer feedback, and take action to reduce the causes of complaints. We continue to improve our complaints service with pro-active calls to customers to resolve their problems quickly.” 

Final recommendation

The Office of Tax Simplification is also independent of but closely aligned with HMRC, but it is managed and funded via the Treasury rather than by HMRC.

If I were on HMRC’s board I would recommend that adjudicator's office should be one small step removed from HMRC itself.  This may allow the complaints process to be more user friendly for the complainant and, paradoxically, a more useful source of data and process improvement for HMRC.

About Wendy Bradley

Wendy Bradley is a retired tax inspector, now working as a freelance journalist.


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