Guidance for providing further information for CHIEF applications

Every decision on whether to grant a further extension to use CHIEF is
based on the specific circumstances presented so the examples below are intended
to provide indicators of what a successful application might

If traders would like to submit additional information that
they believe makes a material difference to HMRC's original decision i.e. detailed
new information that the business concerned weren’t able to provide with good
reason when they initially applied for extended use of CHIEF, please submit this information until the 9th November 2022  by emailing


General principles 

The purpose of an extension
is to give firms already actively engaged in migrating to CDS a little extra
time to complete that work. Firms should be able to show that they have
been actively pursuing this aim e.g. by being active in TDR.

2.      Firms are expected to prioritise their migration
activity and demonstrate this in their applications for an extension – making
every effort to complete migration as quickly as possible.   

3.      Applicants granted an extension to facilitate some
clients or scenarios are expected to use CHIEF only for those scenarios – every
declaration that can be made on CDS should be made on CDS. 

4.      If your client cannot register for CDS because of
issues with their data held by HMRC, they are entitled to continue to use CHIEF
until HMRC resolves the issue. Unless another reason applies, if you are an
intermediary you are entitled to an extension to use CHIEF for those clients

5.      If your clients are able to register for CDS but
have not done so or have done so but not completed a direct debit instruction,
that is not a reasonable case to continue using CHIEF.





anonymised example

Software is
not ready for CDS 

– Clear
explanation of the issue at hand and the reason for the delay 

– Clear
identification of the software provider and their development plan with

– Clear
articulation of the time needed between software delivery and

waiting for additional functionality from their software provider

– Impacted
by [software developer] issues and been advised that the fix will be included
in the next software release (expected [date]). Once deployed we will require
2 weeks to test to ensure messaging working. 

Waiting for
CDS Training

– Clear
explanation of the issue at hand and the reason for the delay 

– Description
of the size of the team needing to be trained, training approach, locations

– Clear plans
showing dates for training 

Small firm
needed additional training for staff; clear evidence of limited availability

…Our CDS
Training is still pending… we are in touch with [provider]…and have booked
sessions with them for CDS training on 14/11 and 28/11 which were the
earliest dates available. 

Customers /
clients not ready 

– Clear
explanation of the issue at hand and the reason for the delay 

– If clients
are not able to register for CDS details of which clients are affected –
names, EORIs etc 

possible to anonymise an example meaningfully


– Clear
explanation of the issue at hand and the reason for the delay 

– Clear
description of the steps taken so far to resolve the issue, including
demonstrating involvement of third-parties where needed.

– Commitment
to dedicate resource / time / people to resolve the issue with an explanation
where needed and date when this will happen. 

needed to complete a software upgrade and integration testing.  This is
a version of the detail provided

– The
implementation of the upgraded software was delayed due to unexpected
compatibility issues… [which] put the testing back by over a month

– The
[third-party]  software upgraded for CDS is loaded on to the test
system, however an issue … has been identified [and a service ticket