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The BSA has responded to the HMRC consultation "Draft legislation: Better use of new and improved-third party data". You can read our response here.
Our response highlights a number of key implementation considerations, including:
Our response highlights a number of key implementation considerations, including:
- a phased implementation approach, with smaller building societies and credit unions brought into scope later once lessons have been learned from larger firms;
- a minimum 60-day reporting window rather than the proposed 14-day deadline;
- alignment with existing reporting frameworks, including Cash ISA, CRS and existing credit union reporting processes;
- clearer guidance on NINO collection, customer treatment and due diligence expectations;
- development of a secure HMRC NINO verification service before verification-related penalties are considered; and
- a proportionate, discretionary penalty framework focused on supporting compliance and improving data quality rather than enforcement.