17 September HMRC manual update gives SME advisers a same-week check on open enquiries

HMRC updated its Enquiry Manual on 17 September. The manual sets out “How HM Revenue & Customs carries out tax enquiry work.” For accountants and SME advisers, that makes today a review point for live enquiries, draft replies and evidence going out this week.

What the source says

This is not a Budget measure or a new penalty regime. It is working guidance from HMRC, published today, on how enquiry officers carry out their work. That matters because open cases often turn on process as much as tax law.

Advisers should compare the updated wording against open enquiries, existing timetables and client responses before anything goes back this week. Even a modest shift in HMRC’s approach can change how a file is framed, evidenced and progressed. For businesses already in discussion with HMRC, timing matters more than commentary, because responses are often being drafted or approved now.

What RecoupIQ’s data shows

Process signal, not distress signal

For RecoupIQ, this lands as a process signal, not a distress signal. A same-day manual change does not, by itself, alter a company’s credit standing. It can, however, alter the time, cost and management attention needed to close a live enquiry.

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Our exposure lens is straightforward: where HMRC interaction is already active, review cadence should tighten because compliance friction can spill into cash discipline. That is most relevant when a business is already juggling weak liquidity, delayed filings or stretched directors. In practice, this kind of update is best read as an early prompt to re-check exposure, not as proof of deterioration.

What this means for UK creditors

What to review this week

If a customer or supplier is dealing with HMRC now, ask whether the update changes any pending response. An enquiry that drags can absorb cash, delay accounts work and distract directors from payment discipline. Those are not dramatic events, but they can still affect when you get paid.

For SME owners, the practical step is prioritisation: flag counterparties with live tax friction, shorten review intervals and watch promised dates closely. That includes payment commitments, filing timetables and any request to extend terms while an enquiry remains open. A RecoupIQ company-level evidence check helps you decide whether to hold terms, chase earlier or escalate monitoring before exposure grows.

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