Once a business joins the scheme, it is the business’s responsibility to make the refund. HMRC’s only responsibility is to ensure that the business has met the terms of the undertaking. Under no circumstances should repayments be made by us to the business’s consumers.
The scheme does not allow the business to retain some of the refund to cover its costs - Regulation 14C(b) - as this would defeat the scheme’s purpose. If an administration fee has been charged this can be recovered by assessment action, see LFT12180.