The settlement opportunity will be open to approximately 23,000 individuals and 4,000 employers, subject to the loan charge, who have not yet resolved their disguised remuneration use with HMRC.

It will also be open to approximately 10,000 individuals and 1,000 employers who have not fully paid their outstanding liabilities to HMRC.

HMRC estimates that this will cost approximately £365m between the settlement opportunity’s launch and 2030-31.

The Treasury said: ‘To access the settlement opportunity, taxpayers will need to engage openly and honestly with HMRC, providing the information HMRC needs to establish the new tax liability due under the opportunity.

‘Where individuals or employers choose not to engage with the new settlement opportunity, HMRC will progress their cases under the existing loan charge legislation.

‘In effect, this will mean that those with outstanding loan charge liabilities who do not engage with the new settlement opportunity are likely to face larger tax bills in the future. This is what broader taxpayers would rightly expect from their tax authority.’

Official Government response to the Loan Charge Review 2025

McCann loan charge review calls for HMRC to offer settlement opportunity | 26 Nov 2025