In the early period of the 'volume compliance', the HMRC Individual and Small Business Compliance (ISBC) enquiry process HMRC attempted to set the bar as to who was a 'competent professional' very high. It cited evidence such as the publication of papers in peer reviewed journals or presenting at professional conferences as being indicators of competent professionalism.

There are several issues with this approach, particularly as it effectively excluded all the 'qualified by experience' competent professionals as it would favour a recent graduate with no industry experience over someone with historic vocational training and 30 years of direct hands-on industry experience.