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Guidance for providing further information for CHIEF applications - Update 4th November 2022
BY:
Niamh O'Connor
7 November 2022
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Every decision on whether to grant a further extension to use CHIEF is based on the specific circumstances presented so the examples below are intended to provide indicators of what a successful application might contain.
If Members would like to submit additional information they believe makes a material difference to HMRC's original decision i.e. new information that was not provided when the initial CHIEF extension application was made, please submit this within 4 business days, by emailing chiefextension@hmrc.gov.uk
This again is only relevant to you if you were a CHIEF Badge Holder and not if you use a third party to complete declarations on your behalf.
General principles
- The purpose of an extension is to give firms already actively engaged in migrating to CDS a little extra time to complete that work. Firms should be able to show that they have been actively pursuing this aim e.g. by being active in TDR.
- Firms are expected to prioritise their migration activity and demonstrate this in their applications for an extension – making every effort to complete migration as quickly as possible.
- Applicants granted an extension to facilitate some clients or scenarios are expected to use CHIEF only for those scenarios – every declaration that can be made on CDS should be made on CDS.
- If your client cannot register for CDS because of issues with their data held by HMRC, they are entitled to continue to use CHIEF until we resolve the issue. Unless another reason applies, if you are an intermediary you are entitled to an extension to use CHIEF for those clients only.
- If your clients are able to register for CDS but have not done so or have done so but not completed a direct debit instruction, that is not a reasonable case to continue using CHIEF.
| Reason | Acceptable evidence | Edited anonymised example |
|---|---|---|
| Software is not ready for CDS | Software is not ready for CDS Clear explanation of the issue at hand and the reason for the delay Clear identification of the software provider and their development plan with dates Clear articulation of the time needed between software delivery and go-live | Intermediary waiting for additional functionality from their software provider 1.Impacted by [software developer] issues and been advised that the fix will be included in the next software release (expected [date]). Once deployed we will require 2 weeks to test to ensure messaging working. |
| Waiting for CDS Training | Clear explanation of the issue at hand and the reason for the delay Description of the size of the team needing to be trained, training approach, locations etc. Clear plans showing dates for training | Small firm needed additional training for staff; clear evidence of limited availability …Our CDS Training is still pending… we are in touch with [provider]…and have booked sessions with them for CDS training on 14/11 and 28/11 which were the earliest dates available. |
| Customers / clients not ready | Clear explanation of the issue at hand and the reason for the delay If clients are not able to register for CDS details of which clients are affected – names, EORIs etc | Not possible to anonymise an example meaningfully |
| Other reason | Clear explanation of the issue at hand and the reason for the delay Clear description of the steps taken so far to resolve the issue, including demonstrating involvement of third-parties where needed. Commitment to dedicate resource / time / people to resolve the issue with an explanation where needed and date when this will happen. | Intermediary needed to complete a software upgrade and integration testing. This is a version of the detail provided • The implementation of the upgraded software was delayed due to unexpected compatibility issues… [which] put the testing back by over a month • The [third-party] software upgraded for CDS is loaded on to the test system, however an issue … has been identified [and a service ticket raised]. |
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