HMRC CC/FS factsheet series: what each one means for an SDLT compliance check

Open a Stamp Duty Land Tax (SDLT) compliance-check letter from HMRC and a small stack of pamphlets falls out. Each carries a code in the pattern CC/FS — short for Compliance Check / Factsheet — followed by a number. The factsheets are published on gov.uk, but the gov.uk index does not group them, and HMRC encloses them by reference rather than reproducing the text in the body of the letter. This piece is a plain-English index of the factsheets that most often appear with an SDLT enquiry, walking each one in turn: who issues it, when it lands, and what its function is in the compliance-check sequence.

The factsheets are statutory information notices in spirit, not opinion pieces. They tell the recipient what HMRC may do under the relevant statute (typically Schedule 36 of the Finance Act 2008 for information powers and Schedule 10 of the Finance Act 2003 for SDLT enquiries) and what rights the recipient has in response. The wording is HMRC's, set out in factsheets the public can read in advance of any compliance event.

The scale of the SDLT population subject to compliance checks

HM Land Registry recorded 848,775 residential transactions across England and Wales in 2025 (Land Registry pp-complete data, fetched 27 May 2026). Of those, 760,361 sat above the £125,000 SDLT nil-rate threshold and therefore generated an SDLT return on the SDLT1 form. HMRC does not publish a public per-year SDLT compliance-check volume, but its Compliance Handbook confirms that risk-profiled checks are the default delivery mechanism for SDLT enforcement, and any one of the 760,361 returns is potentially within scope for an enquiry under Schedule 10 paragraph 12 inside the nine-month enquiry window.

The factsheets at a glance

Source: gov.uk Compliance check factsheet collection page (linked in Sources). The list is not exhaustive — there are over 30 factsheets in the wider series — but these are the ones an SDLT-only compliance check is most likely to enclose.

CC/FS1a — general information about compliance checks

CC/FS1a is the first sheet enclosed with almost every opening letter. It explains, in plain English, that:

• A compliance check is HMRC reviewing a return or a position taken on a return.
• The recipient has the right to be represented by an agent (typically a solicitor or chartered tax adviser).
• HMRC may ask for information and documents; the recipient may decline, in which case HMRC can move to a formal information notice (see CC/FS2 below).
• A check can result in additional tax, interest, and penalties.
• The recipient can ask for a review of any decision or appeal to the First-tier Tribunal (Tax Chamber).

It is the procedural map of the whole process. For an SDLT-only check the relevant statute is Schedule 10 FA 2003 rather than the income-tax framework named in the factsheet, but the procedural rights run in parallel. We covered the Schedule 10 enquiry mechanic separately in our SDLT enquiry window guide.

CC/FS2 — information notices

CC/FS2 lands when HMRC moves from an informal request to a statutory Schedule 36 information notice. The factsheet explains:

• The notice is legally binding.
• The taxpayer normally has at least 30 days to respond (the precise deadline is stated on the notice itself).
• Failure to comply triggers the three-tier penalty structure under Schedule 36 paragraphs 39, 40 and 49A: an initial £300 fixed penalty, then up to £60 per day continuing, then — if the matter reaches the First-tier Tribunal — up to £1,000 per day. We walked the penalty stack in detail in our Schedule 36 information notice penalties guide.
• The taxpayer may appeal certain notices, but tribunal-approved notices restrict the appeal route to reasonable-excuse arguments under paragraph 47.

CC/FS2 typically arrives only after an opening letter has failed to elicit voluntary cooperation. It is not enclosed with every check.

CC/FS3 — visits to business premises with prior agreement

CC/FS3 covers the agreed visit path under Schedule 36 paragraph 10. The factsheet explains:

• HMRC must give reasonable notice and seek the occupier's agreement to visit.
• The taxpayer may decline, in which case HMRC can apply for tribunal-approved entry under paragraph 12 (a separate, more invasive route).
• The visit is for inspection of business premises and records — not for interview as such.
• Domestic premises are out of scope unless used for a business purpose.

CC/FS3 will not usually appear in an SDLT-on-a-main-residence check — the SDLT1 is filed off the conveyancing file rather than a business record — but it can appear if the property is a corporate-held dwelling or a portfolio buy-to-let where the buyer is a trading entity.

CC/FS7a — penalties for inaccuracies in returns

CC/FS7a sets out the Schedule 24 FA 2007 inaccuracy-penalty framework that applies if the compliance check uncovers a mis-stated figure on an SDLT return. The factsheet covers:

• The three-step behaviour test: careless, deliberate but not concealed, deliberate and concealed.
• The penalty ranges, expressed as a percentage of the potential lost revenue (PLR): 0-30% for careless, 20-70% for deliberate, 30-100% for deliberate and concealed (with a non-prompted disclosure attracting the lowest figure in each band and a prompted disclosure the highest).
• The mitigation regime — reductions for telling HMRC about the inaccuracy, helping HMRC quantify the error, and giving access to records.
• The interaction with the "reasonable care" defence: a taxpayer who took reasonable care and made a genuine mistake is not penalised at all under Schedule 24 paragraph 3.

For SDLT, the most common Schedule 24 issue is a mis-stated reliefs claim — typically a first-time-buyer relief claim on a return that did not in fact qualify, or a wrongly-claimed para 3 replacement-test exemption from the additional-property surcharge. Our SDLT refund failed cases guide catalogues the recurring patterns.

CC/FS9 — the Human Rights Act and penalties

CC/FS9 is enclosed when HMRC is considering a penalty. The factsheet explains:

• The European Convention on Human Rights, as incorporated by the Human Rights Act 1998, applies to HMRC penalty decisions.
• Article 6 ECHR rights (right to a fair hearing, including the right against self-incrimination in criminal matters) are engaged where the penalty has a "criminal" character — which, on settled Strasbourg jurisprudence (Engel v Netherlands; Jussila v Finland), captures most tax penalties above the trivial.
• The factsheet does not give legal advice but tells the taxpayer they may wish to take advice before answering further questions that could engage those rights.

In practice CC/FS9 signals that HMRC has begun to assess whether a Schedule 24 penalty applies. It does not itself trigger any new procedural step; it is a notification.

CC/FS10 — suspending penalties

CC/FS10 covers the suspension route for Schedule 24 careless inaccuracy penalties under paragraph 14. The factsheet explains:

• Suspension is at HMRC's discretion and is only available for careless inaccuracy penalties — never deliberate ones.
• HMRC must set "suspension conditions" — typically requirements to improve a record-keeping or filing process — for a period of up to two years.
• If the conditions are met and no further careless inaccuracy occurs in the suspension period, the penalty is cancelled.
• If the conditions are breached or a further careless inaccuracy occurs, the suspended penalty becomes immediately payable.

For an SDLT-only buyer the suspension route is structurally limited because there is rarely an ongoing filing process to "improve" — most buyers file only one or two SDLT1s in a lifetime. HMRC's own guidance in the Compliance Handbook (CH83100) acknowledges that suspension is harder to apply to one-off filings. The factsheet still arrives because the framework is generic, but the practical scope for suspension in a single SDLT case is narrow.

CC/FS13 — publishing details of deliberate defaulters

CC/FS13 covers the public-naming regime under section 94 of the Finance Act 2009. The factsheet explains:

• HMRC can publish the name, address and trade of a "deliberate tax defaulter" once a relevant penalty has become final.
• The threshold is more than £25,000 of tax lost through deliberate default in any given year.
• Publication is on a quarterly gov.uk list, kept up for 12 months.
• Full disclosure of the deliberate default in advance of HMRC starting an enquiry takes the case out of the publication regime entirely.

The naming threshold is high enough that it does not catch the average SDLT case — most SDLT enquiries settle at five-figure additional-tax figures rather than six-figure ones — but on larger transactions, particularly mis-stated reliefs at the £925k+ slabs of the standard residential SDLT schedule, the threshold is reachable. The factsheet is enclosed routinely whenever a Schedule 24 deliberate behaviour finding is in scope.

CC/FS11 — penalties for failure to notify

CC/FS11 covers Schedule 41 FA 2008 failure-to-notify penalties. In the SDLT context, this is the framework that applies if a buyer fails to file an SDLT1 at all (rather than filing an inaccurate one). The factsheet explains:

• The behaviour test runs in parallel with Schedule 24: non-deliberate, deliberate but not concealed, deliberate and concealed.
• The penalty ranges are the same shape as Schedule 24 (0-30% / 20-70% / 30-100% of PLR).
• The 12-month disclosure window after the trigger event materially reduces the penalty in the non-deliberate case (down to 0% if HMRC was not on the verge of asking).

SDLT1 filing deadlines are 14 days from the effective date of the transaction. A buyer who learns six months later that the transaction was chargeable (typically because a relief they assumed applied did not) faces a Schedule 41 penalty calculation on top of the underlying SDLT plus Schedule 53 interest.

CC/FS18(a) — late filing penalties

CC/FS18(a) covers the Schedule 55 FA 2009 late-filing penalties for tax returns other than the income-tax self-assessment return. For SDLT specifically there is a parallel regime under section 76 FA 2003 (£100 initial, £200 after three months, plus tax-geared penalties at six and twelve months), and HMRC's compliance-check practice is to enclose CC/FS18(a) as the closest analogue factsheet rather than maintain a separate SDLT-only late-filing factsheet. The factsheet explains the percentage-of-tax mechanics, the reasonable-excuse defence, and the special-reduction discretion at paragraph 16.

Where each factsheet appears in the sequence

The combination is not arbitrary — each factsheet attaches to a specific statutory power or penalty calculation. A check that produces no penalty exposure ends with CC/FS1a alone. A check that produces a deliberate-behaviour finding can collect five or six factsheets by the time it concludes.

Worked SDLT example: how the factsheets stack on a Manchester purchase

Take a 2025 purchase at £425,000 in Manchester M1 1AE, standard residential SDLT (not first-time-buyer, not additional property). The published HMRC residential rates produce an SDLT figure of £11,250 — verifiable on our stamp duty calculator.

If the buyer wrongly claimed first-time-buyer relief — reducing the figure to £6,250 — and HMRC opened a Schedule 10 paragraph 12 enquiry inside the nine-month window, the factsheet stack at each stage would look like this:

• Day 1 — opening letter. CC/FS1a enclosed alone. HMRC asks for the contractual evidence supporting the first-time-buyer claim (typically the conveyancer's file: prior-residence questionnaire, declaration on the SDLT1).
• Day 30 — escalation. If the records are not produced, CC/FS2 lands with the Schedule 36 information notice.
• Day 60 — penalty position. Once HMRC concludes the relief did not apply, CC/FS7a and CC/FS9 land alongside the closure-notice draft. The PLR is £5,000 (the £11,250 standard figure minus the £6,250 paid). At a careless-behaviour finding the Schedule 24 penalty range is £0-£1,500.
• Suspension possible. CC/FS10 lands if HMRC is willing to consider suspension. In a single-transaction SDLT case the suspension grounds are narrow (per CH83100 above).
• No CC/FS13. The PLR is well below the £25,000 deliberate-default publication threshold.

The actual tax bill in this scenario is £5,000 of underpaid SDLT, between £0 and £1,500 of Schedule 24 penalty, and Schedule 53 interest on the £5,000 from the original effective date. The factsheet stack is the procedural map of how HMRC arrives at each figure.

What the factsheets do not do

The factsheets are HMRC's own published explanations of its powers. They are not:

• Statutory interpretation. The relevant statute (Schedule 10 FA 2003, Schedule 36 FA 2008, Schedule 24 FA 2007, Schedule 41 FA 2008, Schedule 55 FA 2009) is the legal source; the factsheets summarise.
• Negotiation. The factsheets describe HMRC's position; the appeal and review rights they reference are separate procedural rights.
• Advice. None of the factsheets tell the recipient what to do — they describe what HMRC may do and what rights the recipient has in response.

A recipient who is unsure how to respond should take advice from a qualified solicitor or chartered tax adviser before answering substantive questions. The factsheets themselves repeat that recommendation, and the right to representation is the first practical right CC/FS1a sets out.

Wider cross-regime context

The factsheet series is England-and-Wales-and-Northern-Ireland-focused for SDLT specifically (an HMRC tax). Scottish Land and Buildings Transaction Tax (LBTT) is administered by Revenue Scotland and Welsh Land Transaction Tax (LTT) by the Welsh Revenue Authority — both publish their own compliance-check guidance separately. Our SDLT vs LBTT vs LTT cross-regime comparison walks the differences. The procedural overlap is partial: Revenue Scotland uses a similar Schedule 36 analogue under the Revenue Scotland and Tax Powers Act 2014, and the Welsh Revenue Authority uses powers under the Tax Collection and Management (Wales) Act 2016.

Browse more compliance-check guides

For the wider procedural cluster around HMRC SDLT enquiries, see /blog?category=cost-intelligence. The compliance-check sub-cluster — enquiry windows, information notices, penalty mechanics, refund processes — sits inside the wider Cost Intelligence pillar.

Based on 848,775 Land Registry 2025 transactions and HMRC's published Compliance Check Factsheet collection on gov.uk.

This is general information about HMRC's published compliance-check factsheets, not advice on how to respond to a specific compliance check. Speak to a qualified solicitor or chartered tax adviser before acting on anything in a CC/FS factsheet you have received.