HMRC’s Let Property Campaign (“LPC”) has been running for some thirteen years now, having commenced in 2013, and still running. It provides individuals who have been letting out residential property in the UK and/or abroad with a streamlined opportunity to bring their UK tax affairs up to date, by making a voluntary disclosure using an online HMRC portal.
Provided a full and complete disclosure is made, there is no need to meet HMRC face-to-face nor engage in multiple rounds of correspondence about the facts and records available. That said, making any kind of tax disclosure to HMRC can be challenging because one must recount what they had done (and not done), when and explain why. Experienced tax investigation / disclosure specialists understand this part and seek to provide peace of mind to their clients and assist them in identifying old records and alternatives, while keeping abreast of LPC practices and developments at HMRC.
Let Property Campaign Disclosures and Compliance Activities
We track the figures annually and, on our count, HMRC have confirmed that a total of close to £550 million (not just taxes) had been secured by the end of 2025/26, through both its LPC and corresponding ‘compliance activities’. The total number of disclosures received currently sits close to 100,000.
We take this opportunity to remind readers that originally, HMRC had estimated that up to 1.5m landlords had underpaid/failed to pay up to £500 million just in taxes between just 2009 & 2010!
We consider that penalties in LPC disclosures have historically been low, because from experience, we tend to see little checks and challenges made by HMRC after the submission of LPC disclosures. This may be down to disclosures being reviewed by inexperienced HMRC officers who are not tax trained and therefore not able to recognise unusually low penalty rates being offered and/or missing tax years. Also, it’s likely they do not understand the behaviour-based penalty regime well enough.
Anecdotally, our understanding remains that there is a light-touch approach from HMRC in LPC disclosures, due to wanting to restrict resources deployed to run the LPC. It is likely that this is why so many accountants tell us that LPC disclosures they prepared were typically accepted with no checks at all, despite them sometimes having little regard for strict tax assessing rules and penalty regime behaviour categories.
That said, when LPC disclosures are checked more closely sometimes the advisers’ approach is checked in more detail too. That has often led to disclosures being escalated to other teams. From cases that were referred to us at that stage, we can say that they usually showed there was an expectation that HMRC would blindly accept Reasonable Care had been taken. So it followed that the number of tax years in point increased as well as penalties applying or the rates being increased.
Let Property Disclosures: The Figures
Let’s consider the figures concerning the LPC disclosures received by HMRC over the last five years:
| Reporting Year | Disclosures Received | Tax | Interest | Penalties | Total Revenue | Penalty % |
| 2021/22 | 5,392 | £19,512,814 | £2,128,917 | £1,529,187 | £23,170,918 | 7.8 |
| 2022/23 | 10.976 | £27,684,131 | £2,910,380 | £2,018,935 | £32,613,446 | 7.3 |
| 2023/24 | 9,897 | £35,039,615 | £7,730,162 | £2,881,724 | £45,651,501 | 8.2 |
| 2024/25 | 6,490 | £23,485,831 | £7,287,505 | £652,550 | £31,425,886 | 2.8 |
| 2025/26 | 12,660 | £42,835,950 | £26,316,977 | £2,066,919 | £71,219,846 | 4.8 |
The historic records we have, have shown that around 5,000 disclosures were submitted per year like in 2021/22, i.e. before and around the Covid-19 pandemic period. However, the subsequent annual data shows that the number of LPC disclosures being submitted has increased; in fact, it doubled in 2022/23 and 2025/26 interestingly. So, more people are disclosing using the LPC.
Late payment interest follows the number of tax years involved, thus the taxes payable, and the dates on which the taxes were due and payable etc. Notably, interest rates have been much higher in recent years and remain so.
Let Property Compliance Activities: The Figures
Let’s consider the figures concerning the non-disclosures related, let property compliance activities carried out by HMRC over the same period:
| Reporting Year | Tax | Interest | Penalties | Total Revenue | Penalty % |
| 2021/22 | £13,765,358 | £4,756,252 | £2,472,096 | £20,993,706 | 18.0 |
| 2022/23 | £33,233,834 | £11,864,448 | £6,110,436 | £45,098,282 | 18.4 |
| 2023/24 | £58,276,100 | £14,487,634 | £11,526,582 | £84,290,316 | 19.8 |
| 2024/25 | £53,154,095 | £2,561,684 | £11,258,513 | £66,974,292 | 21.2 |
| 2025/26 | £61,493,491 | £15,327,903 | £11,500,238 | £88,321,632 | 18.7 |
Interestingly, the penalty rates being achieved seem much higher than in the LPC disclosures received over the same period; more than double! This should not come as a surprise though as ‘compliance activities’ suggest that these were enquiries / compliance checks that HMRC had commenced, therefore they had presumably ‘prompted’ the disclosures that came thereafter. Conversely, we expect that most of the LPC disclosures made were wholly voluntary, therefore ‘unprompted’ in nature.
The most interesting point here was that the total revenues secured, were a lot higher as a result of HMRC carrying out one-to-one enquiries (compliance checks); more than double in 2024/25!
Deliberate Actions
Previously, we had specifically asked HMRC how many of LPC disclosures were based on “deliberate inaccuracies” in tax returns or “deliberate failures to notify” offences. HMRC had confirmed then that, only c.0.5% (285 out of the 58,574 LPC disclosures made by that time) were as such – i.e. at the most serious end of the behavioural/actions spectrum.
It follows that the number of people recorded on HMRC’s Publishing Details of Deliberate Defaulters (“PDDD”) list has been very small too. One of the key criteria for being named and shamed publicly every quarter is that the underlying behaviour leading to the penalty being chargeable must be ‘deliberate’ as opposed to ‘careless’ or ‘non-deliberate’.
Closing Remarks
The LPC remains open for people to utilise, and that there is no official closure date. So, it is still a good time to review one’s activities and ensure taxes on rental profits are correctly calculated, disclosed and paid etc. Failure to do so, exposes individuals to HMRC’s compliance activities, which bring with it a slow enquiry framework (not a lenient disclosure facility) and obviously larger penalties…
We would encourage seeking out specialist tax disclosures advice where there is a lack of experience in making them and handling corresponding enquiries. This secures the very best possible outcomes for people, based on robust knowledge about strict tax assessment rules and time-limits as well as the various penalty regimes that can apply.
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