HorizonUK Tax Solutions

What is the Worldwide Disclosure Facility?

Answered by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Published 17 July 2026. Last reviewed 17 July 2026.

The short answer

The Worldwide Disclosure Facility (WDF) is HMRC's standing online route for voluntarily disclosing UK tax owed on offshore income, gains, assets or activities. You notify HMRC through the Digital Disclosure Service, receive a disclosure reference number, then have 90 days to calculate and submit your disclosure with payment. It offers no special tax rates and no amnesty: its value is settling on civil terms, with self-assessed penalties usually far lower than if HMRC finds the issue first.

  • Covers UK tax with an offshore element: foreign-source income, assets held abroad, activities carried on wholly or mainly abroad, or funds connected to undisclosed UK tax moved offshore.
  • Runs through HMRC's online Digital Disclosure Service: you notify HMRC, receive a disclosure reference number, then submit within 90 days (complex cases can request 90 extra days, up to 180 in total).
  • The years included depend on behaviour: broadly 4 with reasonable care, 6 for careless errors, up to 12 for offshore matters and 20 for deliberate behaviour.
  • Penalties range from nil (reasonable care) to 200% of the tax, based on behaviour, HMRC's territory category and whether the disclosure was prompted.
  • Full payment is expected when the disclosure is submitted, and late payment interest runs daily from each original due date.

How a WDF disclosure works

You notify HMRC through the online Digital Disclosure Service and receive a unique disclosure reference number. From the acknowledgement of that notification you have 90 days to work out the tax, interest and penalty for every year in scope and submit the disclosure, paying in full at the same time (or agreeing a payment arrangement in advance). HMRC acknowledges a completed disclosure within 15 days and aims to confirm its intended course of action within 90 days of that acknowledgement. Complete, accurate disclosures are normally accepted without a full investigation.

The common trap: treating it as an amnesty

The WDF offers no preferential rates and no immunity. Penalties are self-assessed and depend on behaviour, on whether the disclosure was prompted (for example by a nudge letter) and on the territory involved: nil where reasonable care was taken, 0% to 30% for an unprompted careless error in a category 1 territory, and up to 200% at the top of the scale. Older liabilities can be harsher: offshore tax that arose before 6 April 2017 and was not corrected by 30 September 2018 falls under the failure to correct regime, with a standard 200% penalty that cannot drop below 100% even for a voluntary disclosure. Misjudging the behaviour classification, and with it the years and penalty band, is the most expensive mistake in the process.

What to do before you notify

Gather your records first: the 90-day clock only starts once HMRC acknowledges your notification, so use the time before then to assemble bank statements, rental accounts and your residence history. If a nudge letter prompted you, do not sign the enclosed Certificate of Tax Position without advice; there is no statutory obligation to complete it. Many cross-border cases owe little or nothing once residence, treaty relief or the remittance basis is applied, so check the position properly before anything is submitted. See our full guide to HMRC nudge letters and the Worldwide Disclosure Facility, or our guide to double tax relief if your income was already taxed abroad.

This is general information for the 2026/27 UK tax year, not personal tax advice; speak to a Chartered Tax Adviser about your own position.

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