Preparing the documents for a Let Property Campaign disclosure can feel daunting when several tax years are involved. Gather the rent, expense and tax records first, then check the deadline shown in HMRC’s notification acknowledgement. The disclosure is normally due within 90 days of receiving that acknowledgement, not automatically 90 days after you decide to notify HMRC.
At Felix Accountants, we call this the “Execution Phase.” The 90-day window sounds generous, but when you are dealing with years of missing bank statements and complex tax rules, time disappears quickly. Here is your roadmap to a successful submission.
1. The Timeline: Notification to Settlement
HMRC sets a deadline for the disclosure and payment. If records are missing or you expect difficulty paying, raise the issue early and check HMRC’s instructions rather than assuming a late disclosure will be accepted.
Day 1: Notify HMRC that you intend to make a disclosure. Keep the acknowledgement and note the deadline when it arrives.
Day 2–60: The “Deep Dive.” This is when we reconstruct your rental accounts.
Day 60–80: We calculate the “Tax Gap,” statutory interest, and the behavior-based penalty.
Day 80–90: Formal submission of the disclosure and payment of the total amount.
2. Essential Documentation Checklist
To make an accurate disclosure, we need to move beyond “estimates” wherever possible. You should begin gathering:
Income Records: Tenancy agreements, letting agent annual statements, or bank statements showing rent deposits.
Expense Evidence: Invoices for repairs, insurance certificates, management fee statements, and utility bills for void periods.
Mortgage Data: Annual mortgage interest certificates (usually provided by your lender every January).
Other Income Info: Your P60 or P11D (if employed) or self-employed accounts. Your rental tax is determined by your total income, so we need the full picture to apply the correct tax bands.
Which rental documents matter most to HMRC?
Start with a separate folder for each tax year you may need to review. Put tenancy agreements and letting-agent statements in the income folder, then reconcile them to bank statements and any direct payments made by tenants. For costs, retain invoices and receipts for repairs, insurance, management and other property expenses, along with mortgage statements where relevant. Keep copies of tax returns or other information previously given to HMRC so that amounts already reported are not included again.
If a property was jointly owned, add a note of the owners and the period of ownership. A short schedule showing the property address, rental dates, total rent and expenditure is helpful. The aim is to make the calculation understandable and traceable, not merely to produce a pile of documents. If you are unsure which records apply, request a review before preparing the final disclosure.
3. Dealing with Missing Records
What if you don’t have bank statements from six years ago?
Bank Requests: Most banks can provide historic statements for a small fee, though this can take 2–3 weeks (hence the urgency).
Reasonable Estimates: Reasonable estimates: If older bank statements cannot be obtained, HMRC says you may need to use more recent records as a guide. Explain the method used, keep the calculations and identify which amounts are estimates. Do not assume unrelated market averages will be accepted as evidence.
The Narrative: We must include a note in your disclosure explaining why records are missing and how we reached our estimates.
What if I cannot get older bank statements or receipts?
Missing paperwork does not mean you should omit the income or invent an expense figure. HMRC advises asking the bank for copies of past statements. If they cannot be obtained, more recent statements may sometimes provide a basis for a carefully explained estimate.
Make a note of the bank request, the months missing and any alternative evidence, such as tenancy agreements, agent summaries or invoice copies. Work through the same approach for each affected tax year and record how any estimated amount was calculated. It is especially important to distinguish evidence from an assumption. HMRC may ask why the original statements were unavailable and how you reached the numbers. If the gaps are substantial, seek advice before sending the disclosure. Felix & Co. can help identify what further documents are needed and explain a defensible calculatios.
4. Calculating the “Add-Ons”: Interest and Penalties
Your disclosure isn’t just about the tax. HMRC expects you to “Self-Assess” two other figures:
Statutory Interest
This is not a penalty; it is compensation to the government for not having the money on time. Interest rates for late tax have risen significantly in 2025 and 2026. We use specialized software to calculate interest from the date the tax should have been paid to the current date.
The Penalty Offer
You must make a “Formal Offer” of a penalty. As discussed in previous articles, this is based on your behavior:
Reasonable Care: 0%
Careless (Unprompted): 0% – 30%
Deliberate (Unprompted): 20% – 70%
5. Making the “Formal Offer”
The disclosure includes a formal offer based on the income, tax, interest and any penalties calculated. HMRC may review the figures and request further information before deciding whether to accept the offer. Acceptance should not be described as immunity from further questions if the information is materially incomplete or incorrect.

6. What If You Can’t Pay Everything on Day 90?
If the final bill is larger than expected, do not wait until Day 90 to tell HMRC. * We can negotiate a “Time to Pay” (TTP) arrangement.
- Payment plans are considered on the circumstances. If you cannot pay the full amount, contact HMRC before submitting the disclosure and discuss the information they need to assess a proposed arrangement.
What if I cannot afford to pay the disclosure in full?
Do not ignore the payment issue while you finish the calculations. HMRC expects payment with the disclosure, but its Let Property Campaign guidance explains what to do if you cannot pay the full amount. Contact the campaign helpline as soon as possible and before submitting. HMRC may ask about your income, household outgoings, assets and debts, as well as the amount and timing of any payments you propose.
Keep the disclosure reference number to hand when calling. The purpose is to discuss an arrangement based on your actual finances, not to assume a standard instalment period will be available. HMRC says you should speak to it before submitting the disclosure or payment if you cannot pay in full. If the calculation is uncertain, get the figures reviewed promptly so that the payment conversation is based on a realistic amount.
Frequently Asked Questions (FAQs)
Q1: Can I submit the disclosure before the 90 days are up?
Yes. You can submit as soon as your figures are ready. In fact, submitting early reduces the amount of statutory interest you have to pay.
Q2: What happens if I miss the 90-day deadline?
HMRC may remove you from the campaign. This means you lose the “favourable terms” and lower penalties. They may then open a formal enquiry into your affairs.
Q3: Does HMRC check every single disclosure?
HMRC reviews disclosures and may contact you or your adviser for explanations or supporting records. Its guidance does not promise an acceptance decision within a fixed number of days.
Q4: Do I need to send my receipts to HMRC with the disclosure?
HMRC may ask for the records supporting your figures or for an explanation of estimates. Keep the relevant evidence and calculations in line with the record-keeping requirements that apply to your circumstances and tax years.
Q5: Can Felix Accountants handle the payment for me?
You usually pay HMRC directly using your PRN (Payment Reference Number). However, we ensure you have the exact bank details and references to ensure your payment is allocated correctly to your disclosure.
Beat the Crock with Felix Accountants
The 90-day window is the final hurdle to tax peace of mind. Let Felix Accountants take the lead on the calculations and the paperwork, so you can focus on the future of your property investment.











