Finance Bill 2025-26 briefing: Publication under the new Promoter Action Notices

The ATT has produced a Finance Bill 2025-26 briefing on clause 169 which permits HMRC to publish information about individuals who have received penalties in connection with promoter action notices.

Whilst we support the policy objective of promoting transparency and deterrence, we have significant concerns regarding the scope and proportionality of the information that may be disclosed.

In particular, the power to publish any address used by the recipient risks the public disclosure of residential addresses, creating risks to personal safety and security, especially for individuals with existing safeguarding concerns.

We are further concerned that the safeguards available to affected individuals, including the opportunity to make representations prior to publication, may offer only limited practical protection, particularly where individuals lack familiarity with the process and must incur additional costs to seek professional advice.

We therefore recommend (a) that the legislation be amended to exclude the publication of residential addresses, and (b) that HMRC should be required to exercise a clear statutory discretion to withhold address information where publication would be disproportionate or give rise to safeguarding concerns.