You're signing off on risk you can't see.
Off-payroll compliance sits on your desk. But the contractors, consultants, and service providers creating the exposure? They're scattered across HR, procurement, and business units each with different systems, different processes, and different levels of awareness. When HMRC asks questions, you need answers that hold up.
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The Impossible Position
You're accountable for compliance you don't control.
Off-payroll legislation puts the liability on the organisation and the responsibility lands with tax. But you don't control who gets engaged. You don't control how contracts are written. You don't control what line managers tell contractors about working arrangements.
What you do control is whether there's a defensible process, proper documentation, and evidence of reasonable care. That's what HMRC actually assesses.
The challenges we hear:
- "HR doesn't know about workers coming through procurement"
- "Managers answer CEST questions to get the outcome they want"
- "People leave and we lose all the documentation"
- "The revenue want to see it in practice, not just policy"
What Keeps Tax Leaders Up at Night
| Risk | Impact |
|---|---|
| Personal Professional Standing | As a qualified tax professional with CIOT ethical obligations, compliance failures don't just affect the company, they affect your professional standing. |
| The SAO Certification | Senior Accounting Officer sign-off requires confidence that appropriate arrangements are in place. IR35 is squarely in scope and the CFO relies on you to get it right. |
| Investigation Exhaustion | HMRC investigations drag on for years. They consume your time, your budget, and your credibility. Even if you "win," you've lost months of productive work. |
| Penalties That Compound | Up to 30% penalty for careless errors. Up to 100% for deliberate concealment. On top of the underlying tax, dating back 5-7 years. These numbers get attention at board level. |
"I started questioning some of our internal processes. You're in a meeting with the tax regulator, they're asking questions - and it's extremely uncomfortable. I didn't always know if I could answer with real confidence. What I wanted was to feel certain and in control of our tax position. With CoComply, that's changed. We're now ahead of the market, and at the next meeting the regulator was clearly impressed and comfortable. They asked very few questions. I'm proud of what we have in place and it supports my professional integrity. I have recommended CoComply to many peers."
Evidence Over Assertion
HMRC doesn't care about your policy. They care about your practice and whether you can prove it.
CoComply builds the evidence base that demonstrates reasonable care: every worker identified, every determination documented, every decision auditable. When the revenue asks questions, you're not scrambling to reconstruct what happened three years ago. You're showing them the system that's been running all along.
What Tax Leaders Get from CoComply
Analysing workforce data...Worker Identification
See Who's Really Working for You
Surface every external worker including those buried in service contracts that procurement manages. If they're creating IR35 exposure, you need to know they exist.
What Changes
You can stand behind your position. Every determination is documented, reasoned, and defensible.
You're not reconstructing history. When HMRC asks about a contractor from 2022, the evidence is already there.
You're the solution, not the problem. Instead of being the person who says "no," you're the person who makes compliant engagement possible.
What was important was ease of doing a risk assessment that you can rely on, that's not like the CEST, but also having that hub where you can keep documents and retain them. Because there'll be a change in personnel... everybody might have left the business.