In May and June, ACCA responded to the following consultations:

• HMRC: Promoting electronic invoicing across UK businesses and the public sector – HMRC sought to gather views on standardising electronic invoicing and how to increase adoption of e-invoicing across UK businesses and government departments. We encouraged a cautious approach given the burden already in place for taxpayers and stakeholders from the Making Tax Digital programme. We recommended introducing a voluntary decentralised model.
  
  
• Department for Business and Trade: Small Business Access to Finance – DBT sought views, evidence and experience of applying for and accessing debt finance in the UK. We advocated for improvements that ensure SMEs can access the finance they need to develop and grow. We offered perspectives from our members and research on late payment, SME funding channels, service levels and use of digital technologies.
  
  
• HMRC: Better use of new and improved third-party data – HMRC sought views on opportunities for improving the quality of data acquired under its bulk data gathering powers for tax administration. We highlighted concerns about the integrity and reliability of third-party data and the impact this could have on taxpayers.
  
  
• HMRC: Research and development tax relief advance clearances – HMRC explored potential changes to the advance clearances processes. We encouraged HMRC to consider the positive impact of restricting research and development claims to be processed by professional body regulated agents.
  
  
• Department for Culture, Media and Sport: Financial thresholds in charity law – DCMS sought views on the level at which financial thresholds should be set. We encouraged DCMS to consider the interplay of proportionality and the complexity brought by having different thresholds. We also recommended a commitment to periodic review.
   
• HMRC: Behavioural penalties reform – HMRC is looking to simplify the ways in which penalties are calculated and applied. We welcomed a more consistent, streamlined system, but cautioned against designing the system overly shaped by the actions of the worst players.

ACCA will shortly be submitting responses to HMRC on its ‘Tax Administration Review – improving HMRC’s approach to dispute resolution’ proposals, which seek to help taxpayers identify and access the quickest and most appropriate method of dispute resolution for their circumstance. 

We will also submit a response to CCAB on its ‘Draft Statement of Recommended Practice (SORP) – Accounting by Limited Liability Partnerships 2026’ and HM Treasury on ‘Consumer Credit Act Reform – Phase 1’ and FRC on ‘Introduction of International Standard on Sustainability Assurance (UK) 5000’.

If you have any particular feedback or case studies related to any of these consultations, please contact us on UKPolicy@accaglobal.com.