According to a policy paper published by HM Revenue & Customs on 03 November 2026, the UK government has laid secondary legislation, enabled by Schedule 23 to the Finance Act 2026, to expand third-party data gathering powers across financial institutions and payment service providers. The measure focuses on improving the collection of financial account information and card sales data to make it simpler to pay tax right the first time and reduce non-compliance.
Standing Reporting Obligations for Financial Platforms
Under the new secondary legislation, existing manual notices issued to data-holders under Schedule 23 to the Finance Act 2011 will be replaced with standing reporting obligations. The government aims to modernize data collection by increasing reporting frequency and introducing mandatory due diligence checks on data quality.
In-scope financial institutions and card acquiring service providers will be required to request, collect, and report tax identifiers, such as National Insurance numbers and VAT registration numbers, for matching customer records to taxpayer accounts. Civil society organizations, such as credit unions, are excluded from the requirement to register and provide data.
Operative Date and Implementation Scope
According to HMRC, the operative date for the measure is 06 April 2028. The framework is expected to impact approximately 600 existing suppliers of financial account information and 13 suppliers of card sales data, alongside bringing smaller non-notice entities into scope.
HMRC plans to use the improved third-party data to pre-populate taxpayer returns, improve Pay-As-You-Earn coding, and auto-register customers to the relevant tax regime.
Main picture: Photo by Kelly Sikkema on Unsplash
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