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HMRC published its Alternative Dispute Resolution Guidance today.
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HMRC published its Alternative Dispute Resolution Guidance today. The note says ADR is “when an impartial HMRC mediator assists in resolving a tax dispute outside of the Tribunal or Court.” For businesses with open disputes, the live decision is timing: assess mediation before Tribunal or Court positions harden.
Published on 11 September 2026, the guidance is a process update, not a new relief, concession, or enforcement measure. It explains how HMRC uses mediation and reminds taxpayers that some disputes need not move straight into formal litigation. That matters because once arguments are framed for Tribunal or Court, cost, time, and internal distraction usually increase.
Thin procedural updates are easy to ignore, but timing often decides whether a dispute stays manageable or becomes entrenched. Today’s publication gives advisers and finance directors a clear reason to reopen live HMRC files this week.
Any business with active HMRC correspondence, a pending appeal, or a dispute heading towards Tribunal should review ADR eligibility now. The earlier the review, the more options usually remain.
This update adds no fresh HMRC case numbers, so the useful signal is sequence, not scale. In RecoupIQ’s monitoring, tax pressure rarely appears alone; it often sits beside late accounts, payment stretch, or weaker filing discipline. Where those signals cluster, an unresolved tax dispute can raise exposure by pulling cash and management attention away from suppliers and lenders.
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ADR is an opportunity signal in exposure terms. It marks a stage when a tax issue may still be contained, rather than allowed to become a longer uncertainty.
When tax disputes stay unresolved, the commercial effects often appear elsewhere first. Creditors feel them through slower approvals, tighter cash controls, and more frequent requests for time.
For UK creditors, the practical question is simple: is your customer still early enough in the dispute for ADR to help? If the answer may be yes, review larger balances first, refresh payment expectations, and watch for changes in requested terms. A dispute resolved outside Tribunal or Court may protect cash flow on both sides and reduce the risk of wider collection friction.
Check whether the dispute affects funding covenants, supplier confidence, or near-term cash forecasts. If it does, increase monitoring frequency until the direction of travel is clearer.
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