Compliance Checks
Five Common Mistakes That Trigger an HMRC Compliance Check
HMRC's compliance activity is increasingly risk-based, using data matching across banks, platforms and other government records rather than pure random selection. That means certain patterns of behaviour, even when entirely innocent, tend to draw more attention than others. Here are five of the most common triggers we see in practice, what sits behind each one, and how to make sure you have a confident explanation ready if HMRC ever asks.
1. Round-Number Expense Claims That Repeat Identically
Genuine costs tend to fluctuate — supplier prices change, usage varies, one-off items get bought and then don't need replacing for years. A motor expense claim of exactly £3,000 for three consecutive years, or an identical 'sundries' figure appearing on every return, looks manufactured rather than calculated, even when the underlying spending was entirely genuine.
If your figures genuinely are consistent year on year — a fixed subscription cost, for example — it's worth keeping a short note explaining why, so you're not caught out trying to reconstruct the reasoning from memory later.
2. A Sudden, Unexplained Change in Turnover or Margin
HMRC's systems compare each return not just against sector averages but against the taxpayer's own historical pattern, so a business that has run at a consistent gross margin for years and suddenly reports a significantly lower one — without an obvious explanation such as a new discounting strategy or a one-off stock write-off — is a natural candidate for a closer look, particularly where the change conveniently reduces the tax bill.
A genuine, well-explained reason for the change is usually enough to resolve the query quickly, but only if you can point to it clearly and immediately rather than working it out for the first time once HMRC has already asked.
3. Income That Appears in Third-Party Data But Not on the Return
This is an increasingly common trigger given how much data-sharing has expanded in recent years — from employers' PAYE submissions and banks' interest reporting, to letting platforms, ride-hailing and delivery apps, and online marketplaces now required to report seller income directly.
Where HMRC's systems show income from a specific source that simply isn't reflected anywhere on the submitted return, that gap is one of the most reliable enquiry triggers there is, and one of the easiest for HMRC to identify automatically without any manual review at all.
4. Expenses That Look Disproportionate or Out of Place
A small sole trader claiming subsistence and travel costs at a level associated with a much larger operation, or a business claiming costs that don't obviously relate to its stated trade, invites questions — not necessarily because anything is wrong, but because the figures don't fit the expected shape of that kind of business.
Facing this exact situation?
Get a confidential, no-obligation read on where you stand from a specialist who deals with HMRC every day.
5. Inconsistencies Between VAT Returns and Annual Accounts
Since VAT returns are submitted quarterly and accounts annually, there's an obvious opportunity for the two to drift apart if turnover figures aren't reconciled carefully — and HMRC's systems are well placed to spot exactly this kind of mismatch, since both sets of figures ultimately sit on HMRC's own records.
A Worked Example: How Two Small Flags Become One Big Question
Consider a small café that's run a stable gross margin for three years running. In year four, the margin drops sharply with nothing on file to explain why. At the same time, HMRC's data shows a payment from a delivery platform that doesn't appear anywhere on the submitted return. Individually, either point might prompt a query; together, they significantly increase the likelihood of a compliance check letter landing on the doormat.
Neither point proves anything is wrong. A genuine explanation — higher wastage during a supplier issue, and a reconciliation gap that's simply an accounting oversight rather than deliberate omission — can resolve both quickly and completely. But without a contemporaneous note explaining the margin change, and without matching platform income to the return in the first place, the business is left reconstructing an explanation under pressure rather than having one ready to hand.
How the Five Triggers Compare
None of these five patterns automatically means something is wrong. Genuine businesses regularly have unusual years, disproportionate one-off costs, or a timing difference between VAT and annual accounts that has a perfectly ordinary explanation. What matters is being able to explain the pattern clearly and quickly if HMRC does ask.
| Trigger | What HMRC is comparing | Best defence |
|---|---|---|
| Round-number expenses | Your figures against typical cost variability | A short note explaining any genuinely fixed cost |
| Sudden margin change | Your return against your own history | A clear, contemporaneous reason for the change |
| Missing third-party income | Your return against bank/platform/employer data | Reconciling all income sources before filing |
| Disproportionate expenses | Your figures against sector norms | Evidence the cost is genuinely, wholly business-related |
| VAT vs accounts mismatch | Quarterly VAT data against annual figures | Regular reconciliation between VAT and accounts |
Frequently asked questions
Does one of these triggers guarantee I'll be investigated?
No — these are statistical risk indicators, not proof of anything, and a meaningful proportion of enquiries HMRC opens close with no changes required at all.
Can I fix a mismatch before HMRC notices it?
Yes, and doing so voluntarily is generally treated far more favourably than waiting for HMRC to identify the same issue independently.
How often does HMRC actually cross-check third-party data?
Increasingly routinely — HMRC's Connect system runs this kind of comparison at scale across most returns, not just a manually selected sample.
What if my margin genuinely varies for a good reason?
Keep a short, contemporaneous note explaining the reason as it happens, since this is far more persuasive than an explanation reconstructed after the fact.
Should I worry if my expenses look unusual for my industry?
Not necessarily, but it's worth being able to explain clearly why your business differs from the typical pattern, since HMRC's benchmarks are general, not individual.
Does using an accountant reduce the chance of triggering these flags?
It can help avoid genuine errors and inconsistencies, though it doesn't change how HMRC's automated risk-scoring works on the figures themselves.
Can VAT and accounts differences ever be genuinely correct?
Yes — timing differences between quarterly VAT periods and annual accounting periods are normal, but they should still be reconcilable and explainable if queried.
Is it worth reviewing my own return for these patterns before filing?
Yes — a short self-review against these five triggers before submission is one of the simplest ways to catch an issue before HMRC does, and to have your explanation ready in advance.
Do these triggers apply equally to sole traders, partnerships and companies?
The underlying principle is the same across all business structures, though the specific data sources and sector benchmarks HMRC compares against vary depending on the type and size of the business.
How far back would HMRC look if one of these triggers is flagged?
The initial check usually focuses on the specific year that triggered the flag, though it can extend further back if the pattern uncovered looks like it has been repeated in previous years too.
Is it worth telling HMRC proactively about a mismatch I've just spotted myself?
Yes — flagging and correcting an issue before HMRC identifies it independently is consistently treated more favourably than waiting to be asked, and often resolves the matter far more quickly.
Read the full guide
Related HMRC problems
More from the blog
Making Tax Digital
What Changes to Making Tax Digital Mean for the Self-Employed
Making Tax Digital for Income Tax continues to roll out for the self-employed and landlords — here's what actually changes in practice.
Read the article →HMRC Enquiries
Understanding HMRC's Risk-Based Approach to Selecting Enquiries
HMRC no longer relies on pure chance to decide who to check — here's roughly how the risk-based system works.
Read the article →HMRC Enquiries
What to Do in the First 48 Hours After an HMRC Letter Arrives
The first two days after an HMRC letter lands often matter more than people expect — here's a sensible way to use them.
Read the article →Don't wait for a routine enquiry to become a bigger problem
Tell us what's happened and we'll come back with clear, confidential next steps — no obligation, no jargon.