by Asim Abbas
12 November 2026 
The Contractual Disclosure Facility (CDF): disclosing deliberate tax fraud to HMRC
The Contractual Disclosure Facility (CDF): disclosing deliberate tax fraud to HMRC
If you deliberately did not pay tax, the stakes are higher: HMRC can consider a criminal investigation. The Contractual Disclosure Facility is the route designed for exactly this situation.
- The Contractual Disclosure Facility is for deliberate behaviour that caused a loss of tax.
- A complete and accurate disclosure under a CDF contract means no criminal investigation.
- HMRC says no other disclosure route gives this assurance.
- Deliberate errors can go back up to 20 years, with penalties up to 100%, or 200% offshore.
- Never use the CDF without specialist advice.
HMRC says it is the only disclosure route that gives you assurance that you will not face a criminal investigation, provided your disclosure is complete and accurate.
This guide explains what the CDF is, when to use it and why specialist help matters.
What is the Contractual Disclosure Facility?
According to HMRC’s guide to making a disclosure, the Contractual Disclosure Facility (CDF) is for people whose deliberate behaviour caused a loss of tax. If you make a complete and accurate disclosure under a CDF contract, HMRC will not carry out a criminal investigation. HMRC says it is the only route that gives this assurance.
HMRC defines deliberate as knowing you owed tax but choosing not to tell HMRC, or knowing your return figures were wrong when you submitted them.
When should you consider it?
- you deliberately left income or gains off your tax returns
- you deliberately did not register a business, or hid takings
- a business suppressed sales, for example through till misuse
- you are worried HMRC might treat what happened as fraud
If the error was careless rather than deliberate, the Digital Disclosure Service is usually more suitable. Our guide to choosing a disclosure route compares the options.
Estimate your disclosure
Our free HMRC disclosure calculator works out tax, interest to today and penalties for each year, with PDF or CSV download.
What will it cost?
Deliberate errors can go back up to 20 years. Penalties can be up to 100% of the tax for UK matters and up to 200% for offshore matters, plus interest, although co-operating fully reduces them. Read our guide to penalties and interest.
Fixed-fee accountancy support
Transparent monthly packages for sole traders, landlords and limited companies. Fixed fees agreed upfront, VAT included.
Get a fixed-fee quoteCall 0161 531 4179Why you need specialist advice
- the protection depends on the disclosure being complete and accurate
- by disclosing, you give up your right to silence on what you tell HMRC
- deliberate defaulters can be publicly named if they do not follow the required steps
- company officers can sometimes be personally liable for a company’s penalty
We help you understand where you stand before anything is sent to HMRC, then manage the process with you. Everything you tell us is handled confidentially.
If HMRC has already opened an enquiry
Talk to the officer handling the enquiry and get advice straight away. Early, full disclosure can still reduce penalties. See what to do if HMRC has contacted you and our tax investigation support.
Voluntary disclosure help near you
We help clients make disclosures across the UK, including London, Manchester, Birmingham, Leeds, Liverpool, Bristol, Newcastle, Cardiff and Wales, and in Scotland from Glasgow to Edinburgh. Start with our voluntary tax disclosure service.
What should I do next?
Get specialist advice first, in confidence.
Keep everything, even if it is incomplete.
The protection depends on it.
We will explain your options and next steps.
Frequently Asked Questions
What is the Contractual Disclosure Facility?
A route for disclosing deliberate behaviour that caused a tax loss. A complete and accurate disclosure under a CDF contract means no criminal investigation.
Is the CDF the same as COP9?
The CDF is offered under HMRC’s civil investigation of fraud procedures, often called COP9. Your adviser will explain the process.
How far back does HMRC go for deliberate errors?
Up to 20 years.
What are the penalties?
Up to 100% of the tax for UK matters and up to 200% for offshore, reduced for co-operation, plus interest.
Can I be named publicly?
Deliberate defaulters can be named if they do not follow the required steps, which is one reason to get advice early.
Need help with this? Wingate Accountants offers fixed-fee online accountancy support across the UK. Call 0161 531 4179 or request a quote at wingateaccountants.co.uk.
About the Author
Stephen Reynold
I’m Stephen Reynold, an accountant at Wingate Accountants. I work with sole traders and small companies, turning tax rules into clear, practical next steps.
