A19Delivery risk: AmberGate: pending
Collect the tax already due
Existing action A19, assessed at the same scope.
Provisional single-reviewer assessment; not an approved business case.
- Who and where
- UK taxpayers in the targeted segment (for example small businesses), and everyone who relies on public services. (from the action record) Jurisdiction: UK.
- Result so far
- Range if completed: 13.0–19.0 out of 30 (equal weights; not yet assessed: expected incremental benefit (Bn), incremental affordability (Co))
- Funded now (baseline)
- A large package is already funded and running: Autumn Budget 2024 expected £6.5bn a year by 2029–30 from 5,000 extra compliance staff and 1,800 debt-management staff. Later measures raised this: HMRC’s August 2026 update gives £10bn of additional tax revenue a year by 2029–30 and plans for 5,500 new compliance caseworkers (more than 2,400 compliance staff recruited since Autumn Budget 2024). That yield is already in the fiscal forecasts. Any further package beyond it is a UK Facts proposal. (from the action record)
- The change assessed (marginal)
- Marginal change not yet defined
- Domain home: Follow the money
- In the national plan: Equality and opportunity list
What the evidence supports—and the next decision
Compliance yield includes different kinds of revenue protection; it is not all cash collected in the year or a transferable marginal return.
AI-assisted analytical follow-up · 8 October 2026. Proposed appraisal design; the attributed scores below are unchanged. No funding or delivery agreement is implied.
- Define the change
- Select a tax-risk cohort and additional compliance method beyond existing staffing and digital commitments.
- Test whether it works
- Additional collected receipts net of refunds, appeals and costs over time, with a defensible comparison and separate prevention estimates.
- Establish the cost
- Recruitment, training, systems, litigation and taxpayer burden. Reconcile forecast yield to cash and prevent double counting across tax measures.
- Protect against harm
- Protect proportionality, correct assessments, privacy and accessible appeals.
Read with the outcome evidence and sources in the full assessment. Monitoring proposals are not existing baseline measurements. A numerical benefit or cost score needs evidence for the defined increment, not just the scale of the problem.
Full assessment of Collect the tax already due: ten criteria, scenarios, delivery, costs and monitoring
The ten criteria (0–3)
Each criterion is scored 0 to 3 by the reviewer. “Not yet assessed” means unknown: it is never counted as zero.
Scale and severity (Sc)2 of 3 — Serious harm to a defined group or widespread moderate harm
Reviewer’s reason: Provisional problem-importance judgement from linked site pages; not the scale of achievable benefit.
Increment beyond baseline (Ad)2 of 3 — Specific material change to existing delivery
Reviewer’s reason: Reconcile existing forecast baseline; define cases, staff, legal powers and collection horizon; audit net additional receipts. A missing rating requires a defined marginal change.
Confidence in the proposed action (Ev)1 of 3 — Indirect, mixed, modelled or weak causal support
Reviewer’s reason: Compliance activity can yield revenue; the return from the proposed extra high-wealth focus is not established here.
Expected incremental benefit (Bn)Not yet assessed
Reviewer’s reason: Unknown unless a reasonably defined target-population benefit can be judged; no bonus merely for spanning domains.
Residual harms (Hm)1 of 3 — Material harm/unresolved mitigation
Reviewer’s reason: Due-process burdens; yield lags and double counting existing forecasts.
Incremental affordability (Co)Not yet assessed
Reviewer’s reason: Recruitment/training, systems, litigation, taxpayer compliance and collection costs; gross yield is not net cash.
Delivery capacity (Ca)1 of 3 — Binding scarce resource
Reviewer’s reason: Reconcile existing forecast baseline; define cases, staff, legal powers and collection horizon; audit net additional receipts.
Distribution (Fa)2 of 3 — Mixed or broadly neutral with safeguards
Reviewer’s reason: Provisional distribution judgement for the stated target; verify who pays, who gains and excluded groups.
Meaningful first outcome (Ti)2 of 3 — More than one and up to three years
Reviewer’s reason: First meaningful outcome, not announcement: Collected additional revenue net of costs, error and disputes.
Readiness (Rd)2 of 3 — Named commissioning/allocation/coordination step
Reviewer’s reason: HMRC and Treasury; Cost marginal compliance programme
Four weightings
Normalised as 10 × weighted sum ÷ sum of weights, on a 0–30 scale. Where a criterion is not yet assessed, the range is the lowest and highest result if it were later scored 0 or 3 — not a score, a confidence interval or a rank.
- Equal weights: Range if completed: 13.0–19.0 out of 30. Not yet assessed: expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
- Evidence doubled: Range if completed: 12.7–18.2 out of 30. Not yet assessed: expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
- Scale doubled: Range if completed: 13.6–19.1 out of 30. Not yet assessed: expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
- Cost ignored (the funding gate still applies): Range if completed: 14.4–17.8 out of 30. Not yet assessed: expected incremental benefit (Bn), incremental affordability (Co). Funding gate: not passed.
Funding gate: Not passed — the cost is not yet assessed or no allocation is committed for this scope. Ignoring cost in a weighting never removes the gate.
Delivery risk and gate
Delivery risk shown: AmberReview’s claim: Amber. Best the recorded evidence allows: Amber.
Review’s reason: Recruitment/training, systems, litigation, taxpayer compliance and collection costs; gross yield is not net cash.
Why it is not Green yet
- Scope (population, place and increment) not verified against the delivery baseline.
- No verified owner with the powers in place.
- Delivery capacity not verified.
- Lifetime incremental costs not complete.
- No credible funding (a committed allocation for the scope).
- Safeguards not specified.
- Monitoring lacks a metric, a data source or a baseline.
Green needs verified scope, a verified owner with the powers, verified capacity, complete lifetime costs with credible funding, specified safeguards and monitoring with a metric, source and baseline. Amber means appraisal gaps remain; Red means a material delivery obstacle. Red does not mean unimportant.
Gate: Pending — appraisal incomplete (review label: “Pending: incomplete appraisal”).
Why: Scores incomplete; Funding gate not passed (cost unknown or no credible funding).
The gate is separate from national list membership: being listed does not make an option eligible, and an eligible option need not be listed.
Cost and funding
Lifetime costing: Not established. Review: “Full incremental costing not established in reviewed material”.
- HMRC staff, training, systems, appeals and overheads for a further compliance package (not costed; C-A19-PACKAGE)
Still to cost: Recruitment/training, systems, litigation, taxpayer compliance and collection costs; gross yield is not net cash.
Funding status: not identified.
Owner, powers and capacity
Proposed owner: HMRC and Treasury (proposed, unverified).
Powers: needs a decision or allocation. Capacity: binding constraint.
Powers and capacity read from the review’s Rd and Ca anchors; no proposed owner has agreed to act (the review: “Proposed owners have not agreed to act”).
- England:
- HMRC and HM Treasury; Parliament for new powers; the OBR certifies costings (action record)
- Scotland:
- HMRC and HM Treasury; Parliament for new powers; the OBR certifies costings (action record)
- Wales:
- HMRC and HM Treasury; Parliament for new powers; the OBR certifies costings (action record)
- Northern Ireland:
- HMRC and HM Treasury; Parliament for new powers; the OBR certifies costings (action record)
HMRC administers UK taxes; Scottish and Welsh income tax and devolved taxes (Revenue Scotland, Welsh Revenue Authority) need their own arrangements, not assessed here.
Dependencies, safeguards and risks
Depends on: None recorded.
Safeguards
None specified yet.
Risks and residual harms: Due-process burdens; yield lags and double counting existing forecasts.
Monitoring and measured results
Metric: Collected additional revenue net of costs, error and disputes.
Data source: Not yet named. Baseline: Not yet established.
Measures already on the domain page
- Tax gap, share of tax due: latest 6.4% (tax year 2024–25 (projection, revised in later editions)); baseline not published (United Kingdom).
A page measure is not necessarily the review’s metric; linking the two is an editorial decision still to be made.
Evidence for the outcome
Outcome: Collected additional revenue net of costs, error and disputes.
Compliance activity can yield revenue; the return from the proposed extra high-wealth focus is not established here.
Effect records for this action
- Net tax receipts beyond forecast: size not established (plausible spillover, limited confidence; United Kingdom)
- Costs to compliant taxpayers wrongly challenged: size not established (plausible spillover, limited confidence; United Kingdom)
SWOT points it addresses
- The estimated tax gap was £59.2bn (6.4% of tax due). £20.8bn came from failure to take reasonable care and £9.3bn from error; £36.7bn arose among small businesses. (Follow the money)
- HMRC publishes an annual tax-gap estimate broken down by tax, customer group and behaviour, with an uncertainty rating for each part. (Follow the money)
- Average returns do not establish what more staff would bring: HMRC could not tell the NAO the marginal return to further investment. The large-business directorate generated about £95 per £1 of its staff costs; the broader measure was about £58 per £1, including all HMRC staff and overhead costs and all compliance yield associated with large businesses. (Follow the money)
Review record
Assessment status: Provisional single-reviewer assessment; not an approved business case.
Reviewer: Original assessment author (name not supplied). Reviewed: 6 October 2026.
Scored in the working review of 6 October 2026 on the shared ten-criterion scale (one reviewer); not independently calibrated.
First 90 days (review): Produce a signed scope and current-delivery baseline; Reconcile existing forecast baseline; define cases, staff, legal powers and collection horizon; audit net additional receipts. Obtain incremental costs and an accountable decision before expansion.
Decision route: Cost marginal compliance programme
An editorial screening framework by one reviewer, not a formal appraisal or business case. Proposed owners have not agreed to act.