HMRC’s Customer Compliance Group Explained

Amit’s latest ‘in-brief’ article, HMRC’s Customer Compliance Group Explained was published online (4 March 2026) and in print (6 March 2026) print issue of the Tax Journal.

What is HMRC’s Customer Compliance Group (HMRC CCG)?

The Customer Compliance Group was established in the second half of 2016, after a major restructure to the previously known Enforcement and Compliance Group. As at September 2025, its total staff figure for 2024/25 was 28,074 full-time equivalents (FTEs), almost half of HMRC’s entire headcount.

Prominent directorates within HMRC CCG are as follows:

• Individuals and Small Business Compliance and Wealthy and Mid-sized Business Compliance
  • These two directorates make up the vast majority of HMRC CCG, with around 12,400 staff combined – nearly half of all CCG staff – and therefore represent the core of HMRC’s investigative and compliance resource. In practice, most enquiry letters will come from one of these two directorates.
• Large Business: The LB directorate employs around 2,500 staff to manage around 2,000 of the UK’s largest businesses, measured by turnover.
• Risk & Intelligence Service: RIS, with around 3,300 staff, seeks out intelligence from across the UK and offshore jurisdictions, analyses that intelligence, and assesses the tax risks it presents to the UK Exchequer. RIS has personnel in many countries, sharing intelligence and operational practices with overseas tax authorities.
• Counter Avoidance: The CA directorate uses a range of strategies and evolving legal powers to tackle marketed tax avoidance schemes and arrangements. It focuses on disrupting promoters but also supports users exiting avoidance schemes.
• Fraud Investigation Service: Despite employing around 4,900 staff, FIS manages the most in-depth and intrusive investigations, both civil and criminal in nature. These are not routine compliance cases, but cases involving serious tax fraud, dishonesty or criminal conduct.
  • FIS was formed in 2015 from the merger of Specialist Investigations and Criminal Investigations. Today, it is organised into the Prosecutions Unit, the UK Tax Matters Unit and the Offshore, Corporate and Wealthy Unit.

Practitioners’ takeaways

Most compliance checks will continue to be initiated by ISBC and WMBC. The smallest taxpayers fall within ISBC’s remit, which remains HMRC’s largest single directorate. It is HMRC’s duty to create a deterrence effect, otherwise scrutiny may appear to fall disproportionately on larger and more complex businesses.

While FIS attracts significant attention, only a small proportion of its work involves civil fraud investigations. In 2024/25, just 450 new COP 9 and COP 8 cases were opened, reflecting the resource-intensive nature of these enquiries and HMRC’s selective approach.

Given the relatively small number of businesses monitored by LB, practitioners are less likely to encounter routine compliance correspondence from this directorate. Where contact does arise, it is typically structured, relationship-led and mediated through CCMs.

Here is a PDF proof of the article: HMRC’s Customer Compliance Group Explained and our link to a more detailed look at the Customer Compliance Group.

Serious investigations

These civil investigations are time intensive and resource hungry, but are usually necessary to combat Tax Fraud or large tax loss risks. HMRC’s Fraud Investigation Service investigators manage these, and have more time, give more attention, and are experienced. Remember, HMRC are seeking a recovery of taxes usually, late payment interest, and typically large penalties, for failing to submit correct tax returns or failing to notify HMRC that taxes were payable in the first place. Allegations of having acted deliberately or dishonestly can be common and HMRC are seeking to publicly name and shame people too.

Code of Practice 9

A Code of Practice 9, or COP9, is a civil investigation of suspected tax fraud, where taxpayers are explicitly accused of having acted dishonestly/with fraudulent intent. Taxpayers are given an opportunity to admit (at a high-level) tax fraud within 60 days in return for being able to make disclosures in much more detail later.

Code of Practice 8

A Code of Practice 8, COP8, is a civil investigation into large amounts of tax at risk, but not necessarily due to tax fraud—but it can include that too. It’s not unusual for these to be used against marketed avoidance schemes or arrangements and bespoke tax planning, where HMRC is likely to have made a discovery about historic tax risks.

The investigators are well prepared to argue they have identified new information and culpability— also triggering penalties. There is little possibility of dissuading them in favour of a COP9-style disclosure report and also typically some span years due to their in-depth nature.