IDG47100 - Verifying information for the purposes of HMRC’s functions
Is verifying information that someone already holds a disclosure?
Yes. Even though someone may already hold information, if they ask HMRC to verify whether that information is correct, HMRC is still making a disclosure of information that is protected by HMRC’s duty of confidentiality. This means you should not verify information unless there is lawful authority for you to do so (see IDG40500).
When can HMRC verify information held?
See IDG47000 for an explanation of how HMRC can disclose information about individual HMRC customers where it is necessary for the purposes of HMRC’s functions.
Two common examples arise in connection with disclosure of information by verification.
Verification of VAT registration numbers
Traders or individuals may contact HMRC to seek verification that a VAT registration number is validly held by a particular trader. They may do this because they want to ensure input VAT they are paying to the trader is being properly paid, or in connection with obligations on them under the VAT reverse charge.
You can confirm that a VAT registration number is valid, and/or that it tallies with a name and address where these details are supplied by the enquirer, provided you are satisfied that:
- there is no intent of fraudulent use of the VAT registration details; and
- the enquirer appears to have a legitimate business need.
Such disclosures are necessary so that traders can correctly operate VAT.
Verification of National Insurance numbers
Employers may contact HMRC seeking verification of National Insurance numbers for employees or prospective employees. They may do this because they want to ensure their end of year returns to HMRC are correct or to help satisfy immigration and nationality checks.
You can confirm that a National Insurance number is correct and/or that it tallies with a name and date of birth where those details are supplied by someone who is registered as an employer or pension provider with HMRC provided you are satisfied that:
- there is no intent of fraudulent use of the National Insurance details; and
- the enquirer appears to have a legitimate business need.
Such disclosures are necessary so that employers can correctly operate Pay As You Earn.
Other situations where HMRC is asked to verify information
Above are the two most commonly occurring verification scenarios. If you are asked to verify information held in any other situation remember that verification of information is a disclosure like any other and so lawful authority is needed. If in any doubt you should seek advice from Information Strategy (see IDG90100).
Equally there can be situations where it is particularly important that you neither confirm nor deny information that may be presented to you, i.e. you should make no disclosure at all, for example where a journalist asks Press Office to confirm the veracity of a story in the press about someone’s personal tax affairs. See HMRC’s 'Neither Confirm Nor Deny' policyregarding human intelligence sources.
Further guidance
If you receive a request for verification of information and are unsure how to proceed, please contact Information Strategy for advice. See IDG90100 for contact details.
