United Kingdom | Regulatory Framework
Status: in effect
Effective: 2026-01-28
moderate HMRC publishes GenAI expectations for developers of tax software used for returns and submissions
Guidelines for using generative artificial intelligence if you’re a software developer
I. Regulatory Summary
Tax and legal advisers should update vendor due diligence and internal tool‑approval controls for GenAI‑enabled tax software. Developers should treat HMRC’s transparency, source‑reliability, oversight, and UK GDPR‑aligned security/privacy expectations as baseline compliance requirements.
II. Full Description
Published 28 January 2026 on GOV.UK, this HMRC guidance describes what HMRC considers ‘good use’ of generative AI in commercial software products used to help customers submit information to HMRC. It lists expected characteristics (transparent, reliable, subject to human control, secure, ethical) and states HMRC does not endorse or approve any software developer or product.
III. Scope & Application
HMRC published guidance setting expectations for software developers using generative AI in commercial software products that help customers submit tax returns or other information to HMRC. It sets expectations on transparency, reliance on authoritative legal sources (including legislation and case law), human oversight, security and privacy (UK GDPR), and ethical controls (including bias and accountability).
IV. Policy Impact Assessment
Tax and legal advisers should update vendor due diligence and internal tool‑approval controls for GenAI‑enabled tax software. Developers should treat HMRC’s transparency, source‑reliability, oversight, and UK GDPR‑aligned security/privacy expectations as baseline compliance requirements.
Primary Focus: tax compliance / AI-enabled software governance