We are already aware of numerous businesses which have been accepted and also that have been refused. Please see some useful facts below – we can help to keep you compliant and retain your registration if you have been accepted, or offer assistance in appealing your refusal.
From 1 April HMRC will provide an online look up service to enable retailers and other trade buyers to check their wholesaler’s URN and make sure they are approved before ordering or buying alcohol from them. The results page showing approval should be saved or printed to support the normal due diligence checks.
Businesses will not need to check all their suppliers on 1 April 2017 they can carry out checks before they next trade with each wholesaler. They will need to repeat this check periodically, to ensure their wholesalers remain approved for AWRS. Keep records of the checks as evidence of your due diligence activities. This can be a burdensome task; we can help with regular checks on the validity of your trading partners Unique Reference Numbers. Please visit our AWRS URN Checker for more info.
As a new business, you may have to provide additional information after applying. You would usually supply this during your site visit and it would include:
There is also a section within the application to provide details of your due diligence providers. Need some assistance or advice?
If you were operating in alcohol wholesaling prior to 1 April 2016 you should have already applied online for approval. If you haven’t, then you must apply now.
If you intend to start wholesaling in alcohol you must apply for approval at least 45 days before you intend to trade. New businesses should ensure that they have sufficient business planning in place for HMRC to be able to test they meet their Fit and Proper criteria before making their application
If you have received a refusal letter from HMRC, it doesn't necessarily mean the end for your business. If this is your main source of income, a refusal is a big deal, however you do have the rights to appeal this decision and have 30 days from the date of refusal to do so. You would have to cease trading whilst the appeal is being heard, however this can also be challenged. Please get in contact today for assistance appealing your refusal.
For businesses who are ultimately refused and must cease trading, there are specific 'winding down' periods in which you must sell any remaining stock: If you hold less than £3 million worth of stock then you have 30 days from the date of refusal to sell the goods; if you hold more than £3 million worth of stock then you have 45 days from the date of refusal to sell the goods.
As with previous registrations, such as WOWGR registrations, this now means there are more obligations on your business and more ways for HMRC to penalise you. A heavy focus will be on whether your business maintains sufficient due diligence on trading partners and have all relevant documentation; a few examples of the records HMRC would expect to see are: