Wendy Bradley deciphers HMRC’s public announcements to figure out who will carry the can for the MTD project in the future.
The HMRC organisation chart from February 2018 shows Nick Lodge at the top of the "transformation" area, with Mary Barber as director of the compliance for the future and Making Tax Digital (Individuals) portfolios, and Theresa Middleton as director of the Making Tax Digital (Business) areas beneath him on the organisation chart.
However, this structure may already be out of date, as on 12 June 2018 the list of HMRC major projects appointment letters for senior responsible owners (SROs) was updated. This update also tells us that the MTD for Individuals programme has been formally closed, at least as a government major projects portfolio (GMPP) programme. A number of projects that originally came under the MTD umbrella have been "moved into other programmes".
On 3 July 2018 Ruth Stanier was appointed as both SRO and SBS (Senior Business Sponsor) for the MTD (business) programme, presumably the same Ruth Stanier who appears on the February 2018 organisation chart as the head of "Customs and Indirect Tax Policy".
Who carries the can?
What does it mean to be an SRO? From the face of the appointment letters I rather suspect it may mean something like "designated scapegoat" as it includes the paragraph:
"In addition to your internal accountabilities, you should also be aware that SROs will now be held personally accountable to parliamentary select committees. You will be expected to account for and explain the actions you have taken to deliver the programmes or specific phases or milestones within them. In your case, this means that from the date of signature of this letter you will be held personally accountable and could be called by select committees in respect of the delivery of your programme."
The two roles, SRO and SBS, are part time, and the SBS role seems to be more of an internal one, as owner and champion of the business changes MTD will introduce. The office holder is expected to establish governance of the programme, delegating responsibility for specific areas and keeping the rest of the department's senior management on side and ready to take over the parts of the programme which are finalised to become "business as usual", and to remain in this role until the programme is completed.
So far as the SRO role is concerned, the holder is responsible for ensuring the "delivery of Making Tax Digital for VAT functionality in readiness for VAT mandation from April 2019" and of "of additional Making Tax Digital for ITSA functionality to enable voluntary participation by the majority of ITSA customers".
The appointment letter contains a raft of stern warnings about adherence to the budget in the business case but the guidance pack on the SRO role warns sternly that "you are responsible for securing the resources necessary for success". I'm rather baffled how someone is supposed to do that – organise a £1.3bn bake sale?
Face the committee
The requirement to be accountable to parliamentary select committees is under the Osmotherly Rules, a set of protocols to make it clear who is and is not accountable for the actions of a department.
The section about the SRO role reaffirms that the SRO is "in a special position in that they are expected to account for and explain the decisions and actions they have taken to deliver the projects for which they have personal responsibility. This line of accountability, which should be made clear to SROs in their published SRO appointment letter, relates to implementation (not policy development) for the project."
What have we learnt?
The person at the top of the MTDfB project has changed but the project itself hasn't. MTD for individuals has stopped being considered a separate project but carries on as a series of incremental developments. A different face will appear at the next parliamentary select committee hearing about progress, but they will still be charged with delivering the project, not the shape of the project itself.
We are doomed to mandation of MTD for most traders in the VAT net from April 2019, unless something remarkable happens in the political sphere. Write to your MP, cross your fingers, keep calm and carry on.
About Wendy Bradley
Wendy Bradley is a retired tax inspector, now working as a freelance journalist.