HMRC opens the door to AI-assisted filing disclosure

A consultation on tax agent standards includes a short but consequential section asking whether the use of AI tools in preparing a return or computation should be disclosed, and if so, in what form. The framing is exploratory. Consultations that ask whether something should be disclosed have, historically, been followed by requirements that it is.

The obligation being contemplated is light: an indication that automated assistance was used, with the agent retaining full responsibility for accuracy. That responsibility point is not in question and never has been. No credible reading of existing standards allows an adviser to attribute an error to a tool. What changes is the evidential expectation — the ability to say which work was assisted, and what review was applied.

Practices should begin capturing that record now, because it cannot be reconstructed later. The mechanism can be crude: a field on the job record, a workflow step, a checkbox at review. What matters is that it is contemporaneous and consistently applied. Firms that wait for a final requirement will face a transitional period in which the prior year's work has no record at all.

Two adjacent matters deserve attention. Professional indemnity policies are, in several cases we have reviewed, silent on AI-assisted work rather than explicitly covering it — silence is not comfort. And engagement letters are the cheapest place to set client expectations about tool use, which is worth doing before a client asks rather than after.