ERODG7100 | Administration of the reimbursement scheme post undertaking: the claimant cannot reimburse the consumer within 90 days

HMRC consider 90 days to be a reasonable length of time for the revenue trader to pass any repayment onto the consumers. We would normally expect that the scheme would be ready to be implemented by the time the signed undertaking is received.

Where a revenue trader has been unable to reimburse all their consumers within the 90-day limit, they may request an extension. Where there are good reasons for this failure and the revenue trader has made genuine efforts to reimburse the consumers and to meet the time limit, then an extension may be negotiated. Under no circumstances must an open-ended extension be given.

You should treat each request for an extension on its own merits and the decision as to whether or not to allow an extension is at the discretion of HMRC.