ACCA welcomes the opportunity to respond to the consultation issued by HMRC on Modernising and Standardising Company Tax returns. ACCA has over 100,000 members working in accountancy and finance roles across the UK. From the corporate sector and financial services to public practice and the public sector, our professionals work in all parts of the economy.

Subject to certain concerns being addressed, ACCA supports the focus on transitioning to a standardised, fully tagged format for Corporation Tax computations. It can reduce repeated taxpayer input, trigger fewer enquires, and promote efficiency. Against a challenging economic backdrop for UK businesses, it is important that new compliance obligations remain proportionate.

ACCA believes the cumulative burden of regulation is what has the biggest impact on business. Parallel processes, overlapping obligations, and duplicate requirements make compliance much more time intensive.^[1] The byproduct is reduced emphasis on innovation and growth-led opportunities. This is reflected in Q4 2025 results of the Global Economic Conditions Survey (GECs) that ACCA runs in partnership with the Institute of Management Accountants.^[2] The findings point to a weak economic outlook for many UK SMEs, with confidence levels falling to the second lowest score in the survey’s history. Before addressing select consultation questions, ACCA makes the following suggestions:

• Simplicity, certainty, and stability: ACCA continues to advocate these three principles as the cornerstones of an effective tax system.^[3] When introducing new reporting requirements, HMRC should be mindful of the repercussions on business.
• Inclusion of the term ‘approved’ poses some risk: The proposals would see HMRC assume an expanded set of technical and operational responsibilities. While positive for transparency, such a list must carry the same meaning for HMRC, taxpayers, and agents.
• Alignment with complete accounting periods: ACCA reiterates the importance of alignment with complete accounting periods and not those for tax. This will avoid administrative burdens that may arise from changing halfway through a period.
• The system must maintain degree of flexibility: ACCA views lock tags in software products as helping promote both consistency and standardisation. However, we would like to see more examples of how such requirements operate in real-world contexts. This includes the process that underpins alterations and the blocking of submissions.

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

[1] ACCA comments to House of Lords Industry and Regulators Committee (16 January 2026).

[2] ACCA policy and insights report (15 January 2026), Global Economic Conditions Survey: Q4 2025.

[3] ACCA policy and insights (2023), Twelve tenets of tax, available here.