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Published on 15 September, HMRC's new factsheet says it covers "penalties for CIS payments or returns connected to deliberate non-compliance".
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Published on 15 September, HMRC’s new factsheet says it covers “penalties for CIS payments or returns connected to deliberate non-compliance”. It also says: “This factsheet tells you about the penalties we may charge if we’ve issued a determination under either section 62A or 62B of the Finance Act 2004 for the Construction Industry Scheme (CIS).” For contractors and accountants already in a compliance check, that gives immediate direction on how HMRC will frame the next stage.
The sequence matters more than the label. First, HMRC runs a CIS compliance check. Next, it issues a section 62A or 62B determination.
This factsheet then sets out the penalty position where HMRC alleges deliberate non-compliance. Published yesterday, the note is practical rather than theoretical. It is aimed at people handling live cases now, including subcontractor payment reviews, CIS return queries and adviser responses.
In plain terms, it tells firms what could follow once a determination is already on the table. That makes timing the key point this week. A live case can now be reviewed against a clearer published penalty path.
Our data lens treats this as a process signal, not a balance-sheet event. Our regulatory signal engine flags fresh HMRC operational guidance as a timing cue for account reviews in construction-linked ledgers. The useful change is clarity on sequence: determination first, penalty exposure second.
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That tells credit teams when a tax review may start affecting negotiations, document requests and settlement behaviour. The evidence is the publication itself. The interpretation is that case-handling risk has just become easier to spot earlier.
If a customer or subcontractor mentions a live CIS check, ask which stage it has reached. A routine query is different from a section 62A or 62B determination with a published penalty route behind it. That distinction can affect how quickly a payment issue turns into a wider credit issue.
For SME owners, the practical check is document control. Reconcile CIS returns, payment records, subcontractor status and adviser correspondence before terms are extended or retention is released. That is especially relevant where CIS deductions, margin pressure and disputed invoices are already interacting.
For finance teams, this is not a cue for panic. It is a cue to shorten review cycles, tighten evidence packs and escalate any account where HMRC process risk is growing.
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