Issue Date: February 2015 Overview It isn’t easy to get everything right all the time. We hope that information in this document will help you eliminate some of the things that can cause extra work. We’ve brought together some of the things we see most often or are frequently asked that can cause a return or submission to be rejected or queried. We’ve described some of the common problems and have suggested things you can do to avoid them or solve them. Data security A. Data protection Your responsibilities under the Data Protection Act 1998 (DPA) We do not set any particular security standards for data sent to us from businesses but are happy to work with anyone who needs to send us data to help secure it. Under the DPA, YOU are responsible for the security of personal data until we have received it. B. Sending returns Although you are responsible for the security of the data until we receive it we recommend that all financial institutions should send their data as securely as possible. Links to the permitted formats and methods of submission will be detailed in your notice C. Encryption I SET Returns submitted via our SET service have to be encrypted using the HMRC SET PGP key. Registered users of the service will automatically be supplied with the appropriate key in good time before their submission is due II Non SET users If you are not able to use our SET service we would recommend that you encrypt the data and send it by the alternative means detailed in the notice. If you cannot locate your notice or your hardware or software prevents data encryption, please contact CNI in Cardiff using the contact details at the end of this document Returns being sent by e-mail can only be protected using WinZip Returns being sent on physical media such as CD, DVD or USB stick can be protected using WinZip or any form of self-decrypting software If you use WinZip we recommend that, you use at least v9 and the 256-bit AES option, together with the Mask Password Option. We also recommend that the Page 1 of 11 Document1 September 2011 password selected is at least 20 characters long, contains upper and lower case characters, at least one special character and contains no dictionary words. If you are password protecting your return using PGP you must select the option ‘PGP SELF DECRYPTING ARCHIVE. D HMRC DCDM PGP public key Due to the low usage of the HMRC DCDM PGP public key and the availability of other methods of securely submitting data, the above key has been withdrawn. Returns can be submitted via our SET service OR encrypted using WinZip and submitted by the alternative means detailed in the notice E Return of Media Since 1 April 2010 HMRC no longer returns any media to financial institutions once we have processed Statutory Information Returns. HMRC have introduced a comprehensive data security programme, which is under constant review, and part of this programme required the Department to minimise the risks associated with the movement of data on portable media. In this regard, a key risk was the possibility of media being lost or intercepted in transit so wherever possible we are adapting our processes to reduce the need to move media. We have received legal guidance about our responsibilities concerning reusable media such as USB storage devices. We have been advised that we have no legal obligation to return media although we have previously done this on request. We have looked at ways of deleting data from reusable media but we found the process inconsistent as we were not able achieve a guaranteed level of cleansing. We realise this change will have implications for data providers who use reusable media but we think that, on balance, our obligation to protect customer data must take precedence. We are sorry for any inconvenience this may cause you but we hope that the availability of our Secure Electronic Transfer (SET) service mitigate this Submission information/labels/contact details A submission information I SET All SET returns should be named in accordance with the SET file naming convention. The SET file name contains the following information 1. HMRC reference 2. Sub number 3. Batch number of the file for that reference/sub number/year 4. Total number of batches being submitted on this occasion for that reference/sub number/year 5. Year All five items are required to enable us to process the file correctly Each file needs its own name so that we can identify it. Please do not zip files together or in groups. Without the correct information we will not be able to process the data. To avoid the return being rejected or queried you must always use the SET file naming convention: HMRC Ref_Sub number_Batch number_Total number of batches_Year Example: A9876 _ 03 _ 001 _ 001 _2011 HMRC Ref Sub number Batch number Total number of batches Year Page 2 of 11 Document1 September 2011 Using the naming convention would create a file name that would look like this: A9876_03_001_001_2011 For example, if on this occasion a Financial Institution with the HMRC ref A9876/03 is sending in two batches for 2011 the files (batches) would be called: A9876_03_001_002_2011 and A9876_03_002_002_2011 Batch 1 Batch 2 If the return was a single file (batch) it would be called: A9876_03_001_001_2011 II Physical media Submission documents (media report information) are required to identify the sender and package contents. If the details on the document are incorrect please tell us the correct details by emailing the address at the end of this document. We have redesigned the submission documents to fit onto one page and wherever possible will include them with the notice. The new version also asks for the number of SI 03/3297 (EUSD) cases included on the return where appropriate. If the exact figure is not readily available, a reasonable estimate will suffice. If you are unable to provide this information, your return will not be failed and you will not be penalised. If you need additional submission documents please contact CNI. If you are not able to submit using SET (which reduces the risk of loss of your data in transit) we would very strongly recommend that you send all returns so that they can be delivered during our normal office hours (08.00 – 16.30 Monday to Friday). We also strongly recommend you send them in tamperproof / tamper evident packaging with documentation that details: • HMRC ref • sub number • company name, • year of return • contact details of sender If you send more than one media item (CD, DVD, memory stick) in the same package please make sure each item is clearly labelled so that it is identifiable and we can match it to the paperwork. If you send us anything that holds personal data you must consider the security of that data. You are responsible for the media and the data it holds until it is received by HMRC. B labels (physical media only) Previously very few of the labels that CNI issued were used, so from 2011‐ 12 we will not send out labels automatically. The information required with any physical media sent to CNI will instead be detailed in the notice. We will however still provide labels on request. If you still require labels please e‐mail CNI at the address at the end of this document quoting the reference (including sub number) for which you require labels. When you send us media please make sure you identify each item separately. This should include:HMRC reference and sub number Name of Financial Institution Tax year For example, if you are sending us three CD’s, all three should show the relevant HMRC Page 3 of 11 Document1 September 2011 reference and sub number, your institution's name and the tax year. C Contact Details Your Contact details Please keep us informed about changes to contact details. We are required to send all correspondence to your registered office address but we also need the contact details of the person who submitted the return. Please keep this information up to date HMRC Contacts Unless you are using SET (Secure Electronic Transfer) send your return to the Centre for National Information at the address at the end of this document Do not send your return to anywhere else in HMRC. For advice on how to submit returns or for advice about how to complete the forms contact CNI at the address at the end of this document To request OCR forms please telephone HMRC’s orderline on 0300 200 3610 (8am to 10pm Monday to Friday) Permitted return formats 1 creating your returns Each return type has more than one format for submitting the return and you can submit your return in a single format or in a number of formats. Normally most institutions submit their return under a single sub number which is usually sub 01. E.g. A1234/01. If you are submitting your return as a number of files produced by separate systems or in different formats ideally each file should be submitted under its own sub number. For example if you have a text file produced in London, a separate text file produced in Belfast plus a few exception cases which can be submitted using the HMRC spreadsheet the ideal return should be under 3 sub numbers 01 02 03 London Belfast Spreadsheet If you need additional sub numbers to submit your return please contact us to discuss your requirements as only sub numbers allocated by CNI Cardiff and agreed in advance should be used. If we agree to open new sub numbers we will agree with you short internal descriptions such as those above. These descriptions will only be used in discussions with yourself should a query arise with the return received. Current formats 2 Magnetic Media Specifications As advised in Bulletin 8 we renamed these specifications “Electronic Flat Text File Specifications” Electronic Flat Text Files. This is our preferred option as this type of file loads directly onto our systems. The files are created using the relevant Electronic Flat Text File specifications and are suitable for returns of all sizes. The latest version of the specification can be found on our website and can be accessed using the relevant link in the section ‘What is reportable’ 3 HMRC spreadsheets HMRC has recently developed spreadsheet formats for all of the schemes covered by this document. The spreadsheets can be accessed from our web site using the links in the section ‘What is reportable’. Only the latest spreadsheet published on the HMRC web site will be accepted. The only limitation on the spreadsheet is the number of lines available in the version of Excel that you are using. If you currently submit your return as a text file Page 4 of 11 Document1 September 2011 you can continue to submit in that format. 4 Paper forms Paper OCR forms. These are our least favoured option for a variety of reasons. It is not possible to encrypt paper forms so these are the least secure option. You can only use original forms supplied by HMRC as photocopies and downloaded forms are not acceptable. The forms are usually laborious to complete. The quality of the data is directly affected by the quality of their completion. For these reasons if you are not able to submit a plain text file we would prefer you to use the relevant HMRC spreadsheet. Return problems A Failure to follow the published guidance The BBSI (formerly S17) page on the Gov.uk website contains detailed guidance about how returns should be submitted. We receive requests for assistance from people who have not read the guidance or are not aware it is available. Please ensure that everybody involved in creating or submitting returns knows where they can find the guidance. If you are reading this as an electronic document select the hyperlink above or copy this web address into your browser address bar: https://www.gov.uk/government/publications/type-17-and-18-bank-building-societyinterest-and-other-interest-returns-of-interest-and-eusd/bank-and-building-societybbsi-european-union-savings-directive-eusd-and-other-oi-returns-of-interest 1 Electronic Flat Text Files In the Electronic Flat Text File specifications you are required to create a flat text file consisting of a series of fields. A) The fields must be in the correct order and the correct length. B) If you set the length of a field in the type 1 record the length of the field should be long enough to accept your longest record. All other occurrences of the field in the return should be the length you have set. Normally you will put your information at the start of the field (left justify) unless otherwise detailed in the specifications and add spaces on the right until the field is the length specified. Some fields that you set are linked together, for example ACCOUNT ADDRESS LINE LENGTH and ACCOUNT ADDRESS LINE COUNT. If you set these as 30 and 4 it means that every time an account address is reported we will expect it to consist of 4 fields of 30 characters – total 120 characters (30 X 4). C) If you manually insert or delete information be careful not to inadvertently change the length of the field as this may cause other fields to misalign and the return may be rejected as a result. 2 Spreadsheets It was envisaged that the new spreadsheets introduced for the 2012/13 reporting year would make submissions of returns easier as well as providing a suitable alternative for institutions who had previously reported on OCR forms. We have experienced some errors where it seems the guidance detailed on the spreadsheets has not been followed and this has resulted in returns being failed. Typical spreadsheet failures are: A Inappropriate spreadsheet used Only the latest version of the spreadsheet downloaded from our website will be accepted Page 5 of 11 Document1 September 2011 B C D E Altered spreadsheets Spreadsheets should not be altered e.g. adding or removing columns adding or deleting sheets from the workbook changing the order of the columns Failure to follow guidance For example: not completing mandatory columns, using more characters than detailed (N.B. Excessive characters including spaces will cause the return to misalign leading to failure) the inclusion of unwanted characters such as separators in dates and NINO’s (N.B. Hidden separators such as spaces count as characters) Address problems addresses should be ‘left justified’ in the relevant fields the first two address columns are detailed as mandatory. At least two lines are required to report an address, with the exception of BFPO addresses N.B. Any returns that contain missing addresses for one or more records will be failed Inappropriate characters Some institutions have pasted characters such as ‘tabs’ into the spreadsheets. The use of these types of characters will cause the data to misalign and the return will be failed B Tabs You must not use tabs. Using tabs will cause your return to fail. Always use the space character or fill with zeroes in accordance with the instructions for that field. Make sure you have correctly justified the data. We identified in October 2012 that a number of returns that had failed for containing tabs had been checked prior to submission by importing the data into excel before being converted back to a text file. We have established that converting the excel file back into text inserts tabs into the file. Whilst we encourage the checking of data prior to submission the presence of tabs in the text file will cause the return to fail. One possible solution is to keep a copy of the original text file and if the checks in excel are satisfactory submit a copy of the original file or make any required corrections to a copy of the original file. You are permitted to use carriage return but only at the end of each record. For example, at the end of the Type 1, every Type 2, every Type 3 and the Type 4. In this way each record will begin on a new line and you can usually tell if any fields have gone out of line as they should appear as straight lines down the page. Our systems will process your return irrespective of whether you use carriage return or not. C Incorrect encryption/password problems If we cannot access the return or the data you send us we must reject it. We will require you to resubmit the return having made alterations to enable us to access the data. In some cases we may be able to fix or repair small problems but you should not assume this will be the case. One of the most common reasons is that the password supplied doesn’t work. This may be because the password notified to us doesn’t agree with the password used to protect the file because of a transcription error or an old password was used. Page 6 of 11 Document1 September 2011 Incorrect use of PGP encryption. HMRC DCDM PGP public key Due to low usage and problems encountered with the use of the HMRC DCDM PGP public key we have withdrawn it from use. This does not affect paying agents who submit using our SET service who should continue to use the PGP key supplied by the SET team Note returns submitted on physical media should not be encrypted using the SET PGP key We have received some returns encrypted with PGP which we have been unable to open. We believe that this is due to the user selecting the wrong encryption option. If you are password protecting your return using PGP select the THIRD option “PGP Self-Decrypting Archive DO NOT USE the following options OPTION 1 “RECIPIENT KEYS” OPTION 2 “PASSPHRASE” OPTION 4 “SIGN ONLY” Passwords Please send your password to the email address detailed in the notice Please title your email with your return type and your return reference number. For example, an email containing a password for a BBSI return for A9999 sub return 01 for 2013 should be titled:BBSI A9999/01 2013 Note we will interpret S17, T17, S18 and T18 returns as being BBSI or OI returns. Password Dos and Don’ts To help avoid problems please do not use ambiguous characters such a 0 (Zero) and O (as in Oscar). If your password generation is automatic and generates these types of characters please make sure that these are clearly identified when the password is sent using numbers and the phonetic alphabet as above. This will help us speed up the process and avoid the need to contact you. Please include the reference number, sub number and year of return in the email subject bar. We continue to receive a large number of emails that do not contain reference numbers, sub numbers or year. Passwords should be e-mailed EACH YEAR to the e-mail address detailed in the notice The recipients of the e-mails do not have access to the internet or other methods of decryption than those stated so please do not send links to websites to obtain passwords. Often when we have problems with passwords we have difficulty in identifying who submitted and/or encrypted the return. Please ensure that the documentation that accompanies your submission contains complete up to date contact details. The system is designed to send single passwords. Multiple passwords can be submitted on an Excel spreadsheet attached to the e-mail. Do not submit a password for one return and advise that the password; will apply to all other returns submitted is the same as last time is the same as for last year's return The processing department cannot link passwords submitted in this way. Page 7 of 11 Document1 September 2011 WinZip passwords can be copied and pasted which reduces transcription errors For security reasons you should use a different password for every file submitted, and always follow all guidance for submission. Do not send passwords with the returns, but send them separately. We cannot link passwords from other returns so if you tell us to use the same password as another return we will still have to ask you to send us the password. We never recommend using repeated passwords; you should always use a unique password on every return. D Invalid or incompatible characters If you send returns containing unwanted, invalid or incompatible characters or other information that may affect the processing of the return we may reject them. To reduce the risk of the return being rejected or further enquiries being made please make sure you follow the specifications and avoid using any characters that may cause problems. We can accept electronic returns using upper and lower case characters or any mixture of the two. All Headers and data must be encoded in ISO Latin 1 or EBCDIC character sets. Headers and Data must use the same character set. Only the following characters are allowable: Upper Case Alphabet A to Z Left Hand Parenthesis ( Ampersand & Space Lower Case Alphabet a to z Right Hand Parenthesis) Apostrophe ‘ Full Stop. Hyphen – Oblique or “slash” / Comma, Numbers 0 to 9 Numeric data must be expressed as digits and as printable characters. For example, number 12 should be expressed as character 1 and character 2. Where fractions of numbers are being reported, these should be expressed in decimal and as printable characters, for example 1.25 should be expressed as character 1, character ., character 2 and character 5. It is VITAL that the following characters ARE NOT used in data: Asterisk * Semi-colon; Vertical bar | E Incomplete returns If you identify that you have not included all relevant data in your return please submit a supplementary or additional return containing only the missing data. If you re-submit the full return we could capture the same information twice resulting in unnecessary contact with your customer. If you are not able to submit a supplementary return please contact us to discuss the options available. F Packaging problems HMRC strongly recommends the use of secure, tamper-proof packaging for transporting media. Several problems have been identified with returns received. Returns where the packaging was felt to be insufficient CDs received without cases or in unpadded envelopes. Page 8 of 11 Document1 September 2011 Using ordinary envelopes that were not big or strong enough for the amount of media enclosed, frequently resulting in envelopes being torn or bursting open in transit. Using recycled packaging that had been resealed using sticky tape or staples and giving the impression the package had been tampered with in transit. Returns with insufficient information in the package Cases where no paperwork or contact details were provided. Paperwork and/or media that did not include a reference number. Year of return not quoted. Details on the paperwork that did not match the contents. OCR (paper) returns were received on incorrect/inappropriate forms and had to be resubmitted Changes to reporting a. EUSD reporting A Croatia Croatia joined the EU on 1/7/2013 and savings income paid to Croatian residents from this date should be included on an EUSD return. HMRC has published a Revenue and Customs brief (12/13) which gives full details of the accession of Croatia and actions which will be required by UK Financial Institutions. The brief can be found on Gov.uk using the link above B EUSD reportable addresses We have identified that a number of reports denoted as EUSD information appear to relate to individuals with a UK address. In general, individuals with a current UK residential address should be reported under Sch 23 of FA2011 (previously S17/S18 of TMA 1970). The only exception to this would be a small number of individuals considered to still be resident in another member state although based in the UK such as certain embassy staff. N.B. EU NATIONALS CURRENTLY RESIDENT AND WORKING IN THE UK SHOULD BE REPORTED UNDER SCH 23 OF FA2011 More details can be found in the Revenue and Customs Brief 34/13, which gives full details of our findings and what action we plan to take. The brief can be found on our website using the link above b. Changes to Scheme names The legislation covering the returns previously submitted as section 17 and section 18 of TMA 1970 was updated in April 2011 and these returns are now required under PARAGRAPHS 1 and 12 OF SCHEDULE 23 Finance Act 2011 (FA2011). Because the information to be reported and the acceptable formats were not changed in the interim, these were renamed Type 17 and Type 18. These returns are now to be renamed in line with the type of data they contain. Information previously reported as S17/T17 will now be known as BBSI which represents ‘Bank and Building Society Interest’. Information previously reported as S18/T18 will be known as OI Other Interest We updated the name for personal pension (PP) returns a few years ago and they are now known as RPS RAS (Registered Pension Schemes Relief At Source) returns Page 9 of 11 Document1 September 2011 Although most published documentation will be updated in line with the above, the information type to be detailed in the type 1 record of an OI return will still continue to be S18 (followed by a space to ‘pad’ the field to 4 characters) c. Magnetic Media Specifications – change of name These specifications were originally written when the only method of submitting this type of file was on magnetic media. Following the introduction of optical and electronic media and the availability of our online reporting system SET, the name ‘Magnetic Media Specifications’ is out dated. Going forward these specifications will be renamed ‘Electronic Flat Text File Specifications’. Although the name is changing the formats of the files are not. Where to send your return Unless you are using SET (Secure Electronic Transfer) send your return to the Centre for National Information. Do not send your return to anywhere else in HMRC. HM Revenue & Customs Centre for National Information Ty Glas CARDIFF CF14 5ZG Llanishen Telephone: 03000 582 413 There is more about SET and how it works on Gov.uk E-mail addresses For enquiries and passwords For sending returns To request OCR forms please telephone HMRC orderline on Tel 0300 200 3610 between 8am and 10pm Monday to Friday What is reportable For advice on what is reportable or to download the electronic flat text file specifications or spreadsheet please use the appropriate link below BBSI, OI and European savings directive Schedule 23 to FA2011 and the Reporting of Savings Income Regulations 2003 (SI03/3297) ISA and Junior ISA Guidance Notes Annual Information Returns Registered Pension Schemes (RPS RAS) Guidance Annual Information returns VCT Guidance Annual Information returns Page 10 of 11 Document1 September 2011 Chargeable events Guidance Reporting of chargeable event gains Page 11 of 11 Document1 September 2011