The Worldwide Disclosure Facility (WDF) is HMRC's route for disclosing a UK tax liability connected to an offshore issue: income, gains, assets or activities outside the UK that have not been correctly reported. You notify HMRC through the Digital Disclosure Service, then have 90 days to work out and submit the full disclosure, including payment. If HMRC has flagged your overseas account through international data-sharing, the WDF is very likely the correct facility, not the general disclosure service or the Let Property Campaign.
What counts as an offshore issue?
HMRC's guidance defines an offshore issue broadly. It includes unpaid or omitted tax relating to income arising from a source outside the UK, assets situated or held outside the UK, activities carried on wholly or mainly outside the UK, and anything having the effect of income, assets or activities of that kind. It also covers funds connected to unpaid UK tax that you have moved abroad or that are held abroad, even if the underlying income was originally UK-sourced.
In practice this covers a wide range of situations: interest on an overseas savings account, rental income from a property abroad, gains on overseas investments, or income received through an offshore company, trust or structure.
How does HMRC find out about overseas accounts?
Since 2016, over 100 countries have committed to exchange financial account information automatically under the OECD's Common Reporting Standard (CRS). Banks and other financial institutions in participating countries report account details, including balances and income, to their local tax authority, which then shares that data with HMRC where the account holder is UK tax resident. This is usually how HMRC identifies an overseas account to write to someone about, often through a nudge letter rather than a formal enquiry in the first instance.
Receiving a nudge letter referencing an overseas account does not mean HMRC has proof of wrongdoing. It means your name appears on a list built from data HMRC holds, and it is asking you to check your own position.
How does the disclosure process work, step by step?
The WDF has a clear sequence, verified against HMRC's guidance current as at July 2026.
If your disclosure is complex, for example it involves a legal interpretation issue or a corporate structure, you can request an additional 90 days from the point of notification, giving up to 180 days in total to prepare it. You ask HMRC's Offshore Disclosure Facility helpline for this extra time before your original 90-day deadline runs out.
How do I self-assess my behaviour, and why does it matter?
As part of the disclosure, you are asked to select which of several behaviour descriptions applies to you, ranging from a non-deliberate failure to notify with a reasonable excuse, through carelessness, to deliberately withholding information or submitting an inaccurate return. HMRC's guidance states plainly that this self-assessment determines the number of years you need to disclose, since the assessment periods for each behaviour are set out in statute, and it directly affects your penalty calculation.
HMRC is explicit that if you are unsure which behaviour applies to you, or how to calculate the years or the penalty, you must seek professional advice. Getting the self-assessment wrong is treated as a defect in the disclosure itself, not a minor slip: an inaccurate or incomplete self-assessment can lead to a civil intervention or, in serious cases, a criminal investigation, and HMRC will not guarantee the facility's favourable terms for an inaccurate disclosure.
When is the WDF the wrong route?
The WDF assumes your disclosure is complete, accurate and made in good faith. If HMRC already suspects, or you know, that the underlying conduct was deliberate tax fraud, rather than an error or oversight, the WDF's civil disclosure terms may not be the right route, and the matter can instead fall under HMRC's Contractual Disclosure Facility, known as Code of Practice 9. COP9 is HMRC's civil route for suspected serious fraud, offering the chance to avoid criminal prosecution in exchange for a complete and honest disclosure under a formal contract.
If you are already under enquiry, or your disclosure would relate to a period already covered by a previous settlement or disclosure, HMRC will refer your case for the investigating officer to decide whether it can be accepted under WDF terms at all, and it may attract a higher penalty. If you are unsure whether your situation is a straightforward disclosure or something more serious, that is worth establishing with an adviser before you notify HMRC of anything.
How does this interact with a nudge letter?
Many people arrive at the WDF because they have received a nudge letter about an overseas account, sometimes with a certificate of tax position attached. The letter itself is a prompt to check your affairs, not proof HMRC holds evidence against you, and there is no requirement to sign anything before you have properly checked your records. If your check finds an offshore gap, the WDF is the facility that follows; if it finds nothing wrong, you may not need to do anything beyond keeping evidence that you checked.
Worked example
Example. Consider someone who receives a nudge letter referencing a savings account held overseas, reported to HMRC under the Common Reporting Standard. Checking four years of Self Assessment returns, they find UK income was declared correctly throughout, but interest earned on the overseas account, a modest sum each year, was never included.
Because the issue is offshore, they use the WDF rather than the general disclosure service. They notify HMRC online, receive their DRN and PRN, and use part of the 90-day window to work with an adviser on two things: confirming which years are affected and, critically, which behaviour category genuinely applies, since this was an oversight rather than a deliberate omission. They calculate the tax, interest and penalty for each year using HMRC's published calculators, submit the disclosure with payment inside the 90 days, and receive HMRC's acknowledgement within the 15-day window the guidance describes.
What this means in practice
Reading any letter carefully, and gathering bank statements, exchange records or account correspondence for the years involved, are things you can start today without help.
Self-assessing your behaviour category, calculating interest and penalties, and deciding whether the WDF, the Let Property Campaign, or COP9 is the right facility are best done with an adviser, since HMRC treats an incorrect self-assessment as a defect in the disclosure, not a technicality.
If anything about the letter or your own situation suggests HMRC already views the matter as deliberate, treat that as a different and more serious conversation, and read our Code of Practice 9 page before you respond to HMRC.
Talk to us before you notify HMRC
If you have an overseas account or income flagged under the Common Reporting Standard and are not sure how to respond, we can help guide you with clarity and confidence. The first conversation covers what HMRC's letter actually tells you, whether the WDF is the right facility, and how your behaviour is likely to be assessed. Call 020 8554 2135 or email info@visionconsulting.co.uk, or get in touch via our contact page.
By the Vision Consulting team.
This is general information, not advice. Your position depends on your circumstances.