Large business compliance 2026: key insights from HMRC and Public Accounts Committee reports

HMRC and Public Accounts Committee reports: trust, certainty and compliance

Two reports published in July 2026 provide useful insight into HMRC’s relationship with large businesses and the challenges facing the UK’s large business compliance regime.

HMRC’s Large Business Customer Survey gathered feedback from businesses overseen by its Large Business Directorate, while the Public Accounts Committee (PAC) examined HMRC’s approach to large business tax compliance. Although the reports were produced for different purposes, they highlight several common themes. Large businesses generally report positive experiences of dealing with HMRC, but concerns remain around the time taken to receive responses, achieve certainty and conclude disputes.

For finance directors, tax teams and boards, the findings provide a useful indication of the areas likely to remain a focus for HMRC in the coming years.

HMRC large business survey results: most large businesses report positive experiences

The HMRC survey suggests that relationships between large businesses and HMRC are generally constructive.

More than three-quarters of respondents rated their overall experience of dealing with HMRC as good, with around one-third describing their experience as very good. Qualitative interviews found that positive experiences were often associated with collaborative and pragmatic engagement, a focus on material risks and confidence in HMRC’s technical competence.

Why trust and ease of engagement with HMRC matter for large businesses

One key finding from the survey is the importance of trust.

HMRC’s analysis found that overall experience was shaped primarily by two factors: whether businesses considered HMRC easy to deal with and whether interactions with HMRC led to trust in the department. Seven in 10 businesses agreed with both statements. The survey also found that trust has become a more important driver of overall experience than in previous years.

These findings reflect the reality that, for many large organisations, tax compliance is no longer simply about meeting filing and payment obligations. Businesses increasingly seek certainty on complex tax issues and want timely, practical engagement with HMRC where questions arise.

HMRC Customer Compliance Managers (CCMs): their role in large business tax compliance

The survey also highlights the value businesses place on HMRC’s Customer Compliance Manager (CCM) model.

More than nine in 10 businesses that had dealt with their CCM rated the relationship as good. Respondents consistently praised CCMs’ understanding of commercial context and their ability to take a pragmatic and co-operative approach.

Where experiences were less positive, businesses commonly cited resourcing pressures, staff turnover and reliance on policy teams to progress issues.

The findings reinforce the importance of maintaining open communication with HMRC, particularly where businesses are dealing with complex transactions, international operations or significant tax risks.

HMRC enquiries and tax disputes: why speed and certainty remain key challenges

Despite the broadly positive findings, the survey also identifies areas where businesses believe improvements are needed.

A recurring theme is the time taken to resolve issues and obtain certainty. Qualitative interviews found that negative experiences were commonly linked to slow response times, delays to resolution and prolonged uncertainty. Businesses also reported frustration where issues remained unresolved for long periods despite apparent agreement in principle.

For large businesses, certainty can be critical. Significant transactions, financial reporting decisions and commercial planning often require a clear understanding of HMRC’s position. Only 61% of respondents agreed that HMRC provides certainty in their tax affairs, with a significant decline in the proportion expressing strong agreement, from 20% in 2024 to 14% in 2025.

The survey also found growing concern about the administrative burden of tax compliance, with disagreement that the burden was reasonable reaching its highest level since the survey began in 2015.

Public Accounts Committee report: key findings on HMRC large business tax compliance

Alongside HMRC’s survey, the PAC reviewed HMRC’s approach to managing large business tax compliance.

The committee acknowledged that HMRC’s Large Business Directorate delivers significant compliance results and recognised the generally collaborative approach that exists between HMRC and most large businesses. However, it also identified areas where it believes HMRC should strengthen its approach, particularly in relation to transparency, dispute resolution and public confidence in the tax system.

Large business tax compliance: increasing scrutiny from HMRC and Parliament

The PAC noted that HMRC’s Large Business Directorate generated £15.8 billion in tax revenue during 2024-25, representing around £95 for every £1 spent on staff costs.

This reflects the significant role large business compliance activity plays in protecting tax revenues and demonstrates the increasing focus placed on large business tax compliance by both HMRC and Parliament.

The findings demonstrate the continued focus that HMRC and Parliament place on large business tax compliance.

HMRC special measures and transparency: key issues raised by the Public Accounts Committee

A key theme in the PAC report is transparency.

The committee argues that greater transparency would help strengthen public confidence that compliance risks are being addressed effectively.

The report also examined HMRC’s special measures regime, which was introduced in 2016 to address cases where large businesses repeatedly fail to engage with HMRC in an open and collaborative manner. The regime can impose enhanced monitoring and formal improvement requirements on businesses that meet the relevant statutory criteria.

The PAC noted that no business has been placed into special measures since the regime was introduced and questioned whether the regime remains effective in its current form. HMRC told the committee that the legislative threshold is intentionally high and indicated that it is considering whether legislative changes may be needed.

Why long-running HMRC enquiries remain a major issue for large businesses

The PAC report also highlights the length of time taken to resolve some compliance interventions.

The committee notes that large business enquiries took an average of 17 months to conclude in 2024-25 and are expected to average around 16 months in 2025-26. Cases involving litigation averaged 97 months.

While acknowledging the complexity of many cases, the committee concluded that lengthy resolution periods create costs and uncertainty for both businesses and HMRC.

This mirrors concerns raised by respondents to HMRC’s survey and points to a shared challenge facing both large businesses and the tax authority.

What HMRC and PAC reports mean for large business

The reports paint a broadly positive picture of HMRC’s relationship with large businesses. Most survey respondents reported positive experiences of dealing with HMRC, while the Public Accounts Committee recognised the substantial compliance results delivered by HMRC’s Large Business Directorate.

However, both reports point to continuing concerns around delays, uncertainty and the time taken to resolve issues. They also highlight the importance of effective communication, trust and constructive engagement between HMRC and large businesses.

HMRC large business compliance: how Saffery can help

Our large business tax specialists work with corporate groups across a wide range of sectors on tax compliance, governance, risk management and engagement with HMRC.

We can help businesses:

• Assess and strengthen tax governance frameworks
• Prepare for Business Risk Review Plus (BRR+) reviews
• Manage HMRC enquiries and compliance interventions
• Support discussions with HMRC on complex tax matters
• Review tax risk management processes

If you would like to discuss the implications of these reports for your business, please speak to your usual Saffery contact or get in touch with our team.