HM Revenue & Customs has revised its guidance on the Disclosure of Tax Avoidance Schemes (DOTAS) regime, adding a new provision on penalties. The update, published on 29 May 2026, introduces “Section 21A,” which has been added about penalties. It marks the most significant change to the guidance since tribunal-driven revisions a year earlier.
The DOTAS rules require anyone who promotes or uses arrangements designed to secure a tax or National Insurance advantage to notify HMRC. As the guidance states, those who promote or use an arrangement designed to give a tax or National Insurance advantage may need to make a disclosure. First published in May 2014, the document has been updated repeatedly to track HMRC’s expanding enforcement powers.
The new penalties section signals HMRC’s continued tightening of the framework against promoters and users who fail to report. The previous round of changes, in May 2025, updated numerous sections to reflect recently decided tribunal cases. The full text of the new provision sits inside the detailed guidance document accompanying the publication.