Consultation responses
Our response to HMRC's consultation on introducing a criminal offence for making reckless untrue statements
Submitted 12 August 2026, published here in full. We support the underlying principle but only with an express materiality requirement and clear safeguards. Awareness of a risk must be proved by evidence and not simply retrospectively asserted by HMRC, and carelessness must not be rebadged as recklessness.