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When is the deadline for commissioner's deadline to issue a penalty notice after a notice of intent?

The catalogue records a 6 months period from The giving of the notice of intent. This draft page remains free only until its source, worked example and limits are reviewed.

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Calculation basis and source

Period
6 months
Trigger
The giving of the notice of intent
Counting
The encoded calculator method must be independently documented before publication.
Rollovers and holidays
Holiday, closure and order treatment must be independently documented before publication.

This route remains in preparation until a pinpoint official source is recorded.

  • This is the change practitioners most need flagged. Under the pre-2026 regime the six month limit in the old Schedule 16 para 2(2) was an absolute bar: a penalty notice given more than six months after the notice of intent was invalid. From 5 February 2026 the bar is gone. The replacement duty is qualified by "or as soon as reasonably practicable thereafter", so the six month date is now a target the Commissioner may lawfully overrun. Do not advise a client that the six month date extinguishes exposure.
  • CURRENCY: paras 4(A1) and (A2) were inserted by DUAA 2025 s.101(3)(a) with effect from 5 February 2026 (SI 2026/82, reg 2(t)). SI 2026/82 reg 6 contains a saving that matters for live matters: "The amendments made by section 101 of the 2025 Act do not apply in relation to a case where a notice of intent, within the meaning of paragraph 2(1) of Schedule 16 (penalties) to the 201

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