ACCA welcomes the opportunity to respond to Revenue Scotland’s consultation on the introduction of a digital by default approach to its communications with taxpayers. Given the limitations of continued reliance on paper-based methods, we support the strategic direction of proposals. While Scotland's tax system needs to move with the times, digital first must not become digital only. With broadband connectivity still unreliable in parts of Scotland, any new framework must be built around the needs of all taxpayers.

ACCA believes greater emphasis should be placed on improvements to customer service and ensuring all taxpayers can meet their compliance obligations. In turn, we see value in updating the Charter of Standards and Values to include a standalone section on agent representation. This includes setting out standards of behaviour and values which Revenue Scotland aspires to meet. To mitigate implementation delays and undermining taxpayer confidence, stakeholder engagement must be prioritised at each stage. Alongside responses to select questions, ACCA supplies the following recommendations.

• Update Charter of Standards and Values: ACCA recommends inclusion of a standalone section for professional agents. Key areas include mechanisms which embed taxpayers’ exercising the right to representation, likewise (when chosen) that both taxpayers and agents receive the same information. The same applies to accessibility considerations and safeguards for those digitally excluded.
• Simplicity, certainty, and stability: ACCA considers these principles fundamental to an effective tax system. Consistent terminology, response times, standardised templates, and common authentication can promote these principles. 
• Future proofed design: System design must account for the needs of diverse stakeholders and align with existing digital platforms. The transformation must be supported, for example, through help desks, customer education, and service teams to manage new systems.
• Security frameworks: Multi-factor authentication, identify verification, secure portals, and agent authorisation remain critical components. Revenue Scotland should map out its approach to achieving consistency in these areas.
• Transition road map: Phased implementation and issuance of transformation roadmaps will help build confidence and minimise disruption. Stakeholders should have a clear line of sight over Revenue Scotland’s intended direction of travel.
• Best practice insights: Besides the work of HMRC, ACCA draws attention to the transformation journeys of other jurisdictions, including that of the Inland Revenue Department in New Zealand. Their customer first focus, tailored stakeholder engagement, and multi-stage implementation can help guide Revenue Scotland’s own thinking.

To read the response in full, please download the consultation document found on this page.