Consultation outcome

Draft regulations: Mandatory Disclosure Rules

This consultation has concluded

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Detail of outcome

The government has published its response to the consultation on the implementation of the Organisation for Economic Co-operation and Development (OECD) Mandatory Disclosure Rules for CRS (Common Reporting Standard) Avoidance Arrangements and Opaque Offshore Structures.

Two decisions on the design of these rules are included in the document:

  1. the period for reporting of pre-existing arrangements entered into since 29 October 2014:
    having considered the balance between burdens on business and the likely compliance benefits of the data, the government has decided that reporting pre-existing arrangements should only be required from 25 June 2018

  2. Online manual reporting:
    the government is not providing an online manual system for businesses to report, so businesses will be required to report to HMRC using XML software. The government has to balance up the costs faced by business with the additional time and costs for government of providing a manual system. However, by requiring the reporting of pre-existing arrangements from a later date than initially envisaged, the government has significantly reduced burdens on business, which should support businesses and help balance the potential additional burdens of not providing manual reporting

The regulations will come into force in the first half of 2023. At the same time, the International Tax Enforcement (Disclosable Arrangements) Regulations 2020 (SI 2020/25) (the regulations implementing the EU’s DAC6 rules in the UK) will be repealed.

HMRC will continue to work with stakeholders, including those who responded to the consultation, to draft HMRC guidance. This will provide help to intermediaries and taxpayers so that they can meet their obligations under these regulations.

Original consultation


We welcome views on the design of draft regulations requiring disclosure of certain arrangements to HMRC.

This consultation ran from

Consultation description

At Budget 2021, the government announcement that it would implement the Organisation for Economic Cooperation and Development’s (OECD’s) ‘Model Mandatory Disclosure Rules for Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures’.

The model rules require taxpayers and intermediaries to disclose information on these types of arrangements and structures to HMRC. These regulations will replace similar EU rules introduced previously.

You can read the consultation document and the draft regulations on this page.


Published 30 November 2021
Last updated 24 November 2022 + show all updates
  1. A summary of responses to the consultation has been published.

  2. First published.