The Treasury has now signed off a small but commercially important change to HMRC's naming regime. According to the statutory instrument published on legislation.gov.uk, the Finance Act 2009 (Publishing Details of Deliberate Tax Defaulters: Increase to Threshold) Order 2026 was made on 9 September 2026, laid before the House of Commons on 11 September 2026 and comes into force on 2 October 2026. (policyindex.ai) From that date, the publication trigger in section 94(1)(b) of the Finance Act 2009 rises from £25,000 to £50,000. In plain terms, HMRC's power to publish the names and details of people or businesses penalised for deliberate defaults will apply only once the higher threshold is crossed, alongside the rest of the statutory conditions. (policyindex.ai)

For business readers, this is less about tax being forgiven and more about public exposure being recalibrated. A deliberate default remains a serious compliance issue either way; what changes here is the point at which a case can move into HMRC's public naming process. (gov.uk) That means cases sitting between £25,000 and £50,000 should, in practice, fall outside the naming threshold once the Order is live, although that is an inference from the new cut-off rather than a separate figure set out by HMRC. HMRC's July Tax Information and Impact Note also says the measure does not alter tax administration obligations for compliant businesses and is not expected to add to their administrative burden. (gov.uk)

HMRC's July policy paper is fairly direct about the reasoning. The department says the threshold is being lifted to broadly reflect inflation since the original level was introduced, to keep the regime proportionate as more information is published, and to focus naming on more serious deliberate non-compliance. (gov.uk) That wider reform matters. The same policy package says HMRC wants to publish more detail about the behaviour behind a case, including a description of the deliberate non-compliance and the tax and penalty types involved, and to start publishing details linked to personal liability notices after Royal Assent to Finance Bill 2026-27. (gov.uk)

For SMEs and advisers, the practical issue is reputation. HMRC says publication can bring extra media or public interest, and its general guidance says published details stay online for no more than 12 months from first publication. A higher threshold reduces the pool of cases that can reach that stage, even if it does not remove the underlying penalty risk. (gov.uk) The impact note also says around 800 individuals and businesses a year are touched by this part of the deliberate defaulters framework. HMRC adds that it will hear representations before publication and will not publish where there is a safety risk, which is a reminder that the regime is designed as a public deterrent rather than an automatic naming exercise. (gov.uk)

There is a trade-off here that ministers have not tried to hide. Raising the threshold should mean fewer names on future lists - again, that is an inference from doubling the cut-off - but the names that do appear are set to come with richer case detail once the wider reform is in place. In short, the effect looks more selective, not necessarily softer. (gov.uk) Businesses should also note what has not changed. HMRC's current guidance still says a person will not be published if they earn the maximum reduction of penalties by fully disclosing the defaults, so early and complete engagement remains important for anyone trying to contain both penalty exposure and reputational damage. (gov.uk)

There is no sign in HMRC's published assessment that this is meant as a softer compliance stance. The July note says the measure is not expected to have an Exchequer impact, a significant macroeconomic effect or extra administrative cost for business, which suggests the government sees it as a calibration of the publicity rules rather than a shift in enforcement policy. (gov.uk) For October 2026 planning, the message is straightforward. The public naming line for deliberate tax defaulters is moving from £25,000 to £50,000 on 2 October 2026, and HMRC's own policy paper says the higher threshold will feed into the November 2026 publication cycle. For advisers, that changes the reputational maths around mid-sized cases, but it is not a reason to treat deliberate default penalties any more lightly. (policyindex.ai)