FHDDS51430 | Penalties, sanctions and offences: penalties – policy: Trading without approval - Non-deliberate trading without approval

From HM Revenue & Customs · VAT Fulfilment House Due Diligence Scheme

Trading without approval which is non-deliberate is neither

• deliberate and concealed

• deliberate but not concealed.

The non-deliberate penalty applies unless the behaviour is deliberate or the person has a reasonable excuse. See CH71500 for guidance on reasonable excuse.