HMRC’s ‘Digital by Default’ response strikes right balance

Published on 12 March 2012

Having long advocated that digital by default should not mean compulsion, we are pleased that HMRC’s response to the Digital by Default consultation recognises the need to take an inclusive approach and not a mandatory, statutory one. However, we believe this approach should be consistent across all taxes, including VAT.

HMRC’s ‘Summary of Responses: - Digital by Default’ seems to us to strike a sensible balance between promoting use of digital channels while retaining paper channels for the foreseeable future.

HMRC appear to acknowledge the particular needs of the digitally excluded - people living in areas where broadband is weak or non-existent and those for whom digital interaction is difficult or impossible because of age, ill health, disability, poverty, lack of language skills, and so forth.

There is a vital balance to be struck between encouraging migration to digital as the default channel and ensuring no one is left behind. Digital by default should mean improving the digital channels so that people naturally come to them without being compelled. This does not mean that users of non-digital channels should be treated as second-class citizens – paper and other non-electronic means of interacting with HMRC should always be there for the minority who need it.

Consequently, HMRC’s policy of digital compulsion in fields such as VAT and PAYE (with very few exemptions from the requirement being provided for in the law as it stands) now looks increasingly out of step not only with wider government policy, but with more enlightened thinking within HMRC itself.

LITRG welcomes assurance that any changes coming as a result of tax simplification will be looked at from the perspective of this response on Digital by Default.

Click here to read LITRG’s response to HMRC’s consultation on ‘Digital by Default’ submitted on 31 October 2011.


Contact: Robin Williamson (please use form at