Modernising Revenue Scotland's tax administration framework – communications from Revenue Scotland to taxpayers: Consultation Analysis

6. Analysis Part D - Scottish Government Impact Assessments

This section of the consultation document asked for views in relation to various Impact Assessments as part of the consideration of potential legislative changes related to communication from Revenue Scotland to taxpayers.

20. Do you have any information which could inform a draft Business and Regulatory Impact Assessment (BRIA) relating to the proposals set out in this consultation?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Transitional costs and longer-term benefits

One professional body highlighted that the proposals are likely to give rise to both transitional costs and longer-term benefits, with impacts varying across different types and sizes of organisation.

They noted that implementation of increased electronic communications may require investment in systems, secure communication channels, and processes to manage digital delivery and access. Ongoing administrative requirements could include maintaining accurate taxpayer contact details, managing opt-out requests and ensuring appropriate agent authorisation and access arrangements are in place.

For taxpayers and agents, it was suggested that changes to internal processes and increased monitoring of communications may be required to ensure deadlines and obligations are met.

At the same time, they considered that increased use of electronic communications could deliver longer-term efficiencies through faster communication, reduced reliance on postal services, improved record-keeping and more timely engagement between Revenue Scotland and taxpayers.

Impacts on different types of organisations

One professional body highlighted that the impacts of the proposals may vary significantly depending on organisational size and existing digital capability.

It was suggested that larger organisations and those with established digital infrastructure may be better placed to adapt quickly and realise the benefits of digital communications. By contrast, smaller businesses, sole practitioners, and organisations with more limited resources may face proportionately greater implementation costs and administrative burdens.

The respondent also noted that organisations supporting digitally excluded or vulnerable taxpayers could experience increased demand for advice and assistance, particularly during any transition period.

Impact on public services and support channels

An individual respondent suggested that increased use of electronic communications could place additional pressures on public services and support channels. The respondent noted that taxpayers who are unable to engage digitally may require greater assistance and argued that the BRIA should account for the potential resource implications for public bodies and advice services.

One professional body similarly highlighted that organisations supporting digitally excluded or vulnerable taxpayers could experience increased demand for support during any transition period.

Need for ongoing assessment

A professional body and an individual respondent emphasised the importance of assessing the costs and benefits associated with increased use of electronic communications.

The professional body highlighted the need to consider impacts on taxpayers, agents, organisations of different sizes and the wider tax compliance market. The individual suggested that the BRIA should quantify the costs associated with digital exclusion, including effects on taxpayers, support services, and compliance levels.

21. Are you aware of any examples of particular current or future impacts, positive or negative on young people, (children, pupils, and young adults up to the age of 26) of any aspect of the proposals in this consultation?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Digital access and exclusion

Most respondents did not identify any specific impacts on children and young people arising from the proposals. However, one individual respondent highlighted potential risks associated with digital exclusion.

The respondent suggested that some young people, particularly those living in rural and island communities, may experience barriers to digital engagement due to poor broadband connectivity or limited access to digital devices. They noted that some young people may rely on shared devices or have limited opportunities to access online services, which could affect their ability to receive and respond to important communications.

The same respondent also suggested that missing important electronic communications could increase anxiety and potentially contribute to non-compliance among young people who face barriers to digital access.

Equality of access

The same respondent suggested that a predominantly digital approach could disadvantage young people without reliable access to digital services. They emphasised the importance of ensuring that any future communications framework remains accessible to all taxpayers, regardless of age or personal circumstances.

Potential benefits and support requirements

One professional body highlighted that younger taxpayers may benefit from familiarity with digital systems, which could support engagement and responsiveness when interacting with Revenue Scotland.

However, the organisation also noted that younger taxpayers may have limited knowledge or experience of the tax system and therefore continue to require clear guidance and support. It cited findings from Scottish Government research indicating that understanding of the devolved tax system is not universal, suggesting that support and explanatory information would remain important regardless of communication method.

22. Are you aware of any examples of potential impacts, either positive or negative, that you consider any of the proposals in this consultation may have on the environment?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Reduced paper use

Several respondents identified potential environmental benefits associated with greater use of electronic communications.

One professional body suggested that increased use of digital communications could have positive environmental effects through reduced paper consumption and lower transport requirements associated with postal services. An individual respondent also highlighted the potential to reduce unnecessary printing and paper use.

Environmental impacts of digital infrastructure

While recognising the potential reduction in paper use, several respondents cautioned against assuming that electronic communications are inherently more environmentally sustainable.

One professional body noted that any environmental benefits would need to be considered alongside the additional energy required to operate digital systems, particularly where technologies such as artificial intelligence are used.

Several individual respondents argued that digital communications also consume energy and generate environmental costs through the operation of data centres, server infrastructure, and electronic devices. One respondent further suggested that some taxpayers may continue to print electronic communications, reducing any potential environmental savings.

Another individual respondent also highlighted the environmental impacts associated with electricity consumption, cooling requirements, and water usage for data centres. The respondent suggested that these factors should be considered alongside any reductions in paper use and transport emissions.

Need for a balanced assessment

A common theme among those who commented was that both digital and paper-based communications have environmental costs and benefits.

One individual respondent explicitly noted that the environmental impacts of paper production and delivery vehicles should be weighed against the energy demands of digital infrastructure. Similarly, one professional body and an individual respondent suggested that any assessment should consider the wider environmental impacts associated with digital systems as well as any reductions in paper use.

Overall, respondents who commented on environmental impacts generally considered that both electronic and postal communications have environmental implications. They emphasised the importance of taking a balanced approach when assessing the potential environmental effects of the proposals.

23. Are you aware of any examples of how the proposals in this consultation may impact, either positively or negatively, on these with protected characteristics?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Age, disability, and digital exclusion

Most respondents did not identify specific impacts on people with protected characteristics. However, those who did respond generally focused on the potential for adverse impacts if electronic communications become the default method of communication.

Two individual respondents suggested that older people and disabled people may face barriers in accessing digital communications and services. They highlighted the risk that increased reliance on electronic communications could disadvantage those who are unable or less able to engage digitally.

One individual respondent highlighted potential impacts on older people, disabled people and low-income households who may have limited access to reliable internet services. The respondent suggested that these groups already face barriers when accessing public services and could experience additional difficulties if communications are primarily delivered electronically.

Another individual respondent noted that carers may not always have access to the email accounts of people they support, potentially creating difficulties in managing Revenue Scotland communications on behalf of disabled individuals.

A professional body noted that digital communications may improve accessibility for some users, particularly where assistive technologies are used. However, it stressed that risks of exclusion would need to be mitigated through inclusive design, appropriate safeguards and alternative communication options.

Importance of alternative communication channels

Both an individual respondent and a professional body highlighted the importance of maintaining alternative methods of communication for those who are unable or unwilling to engage digitally.

The individual respondent suggested that non-digital options should remain readily available, while the tax professional body emphasised that alternative communication channels should be properly resourced and offer a service equivalent in status and timeliness to digital communications. The organisation considered this important to ensure that digitally excluded or vulnerable individuals are not disadvantaged.

24. Are you aware of any examples of potential impacts, either positive or negative that you consider any of the proposals in this consultation may have on groups or areas at socio-economic disadvantage (such as income, low wealth or area deprivation)?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Digital access, affordability, and inequality

Most respondents did not identify specific impacts on groups or areas experiencing socio-economic disadvantage. However, those who did generally focused on the potential consequences of digital exclusion.

Several individual respondents highlighted concerns about access to digital technology. One respondent noted that individuals on lower incomes and those living in areas of deprivation, may be less likely to have reliable internet access, appropriate digital devices or the skills and confidence required to engage with digital services.

Two respondents suggested that these barriers could result in taxpayers missing important communications and experiencing difficulties meeting their obligations, while one respondent also highlighted the potential for increased stress among low-income taxpayers.

It was similarly highlighted by a professional body that socio-economic factors may limit access to digital communications, including the availability of devices and internet connectivity. The organisation noted that the costs associated with maintaining access to digital services may have a proportionately greater impact on individuals and households experiencing financial hardship.

Mitigating impacts

One professional body stressed that continued access to non-digital communication channels would be essential to avoid widening inequalities.

25. Are you aware of any examples of how the proposals in this consultation might impact, positively or negatively, on island communities in a way that is different from the impact on mainland or other areas?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Digital connectivity and access

Most respondents did not identify specific impacts on island communities. Those who did generally focused on digital connectivity and access to services.

One professional body and an individual respondent highlighted that broadband connectivity can be less reliable in island communities, which may make it more difficult for some residents to engage with electronic communications. The individual respondent suggested that increased reliance on digital communications could create hardship for island residents and potentially increase costs where alternative means of access are required.

Postal communications and transport disruption

It was noted by one individual respondent that mail deliveries can take longer than on the mainland due to weather conditions and ferry disruptions. Another respondent similarly highlighted the impact of transport disruption on postal services but suggested that digital communications could be beneficial where postal delivery is delayed, provided reliable internet access is available.

Mitigating impacts

One professional body emphasised the importance of a flexible approach, including continued access to postal communications. Similarly, an individual respondent suggested that island communities should not be disadvantaged compared with mainland areas and highlighted the importance of retaining alternative communication channels where needed.

26. Are you aware of any examples of how the proposals in this consultation might impact, either positively or negatively, on rural communities on mainland Scotland?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Connectivity and digital access

Most respondents did not identify specific impacts on rural communities. Those who did generally focused on digital connectivity and access to services.

One tax professional body and two individual respondents highlighted that broadband connectivity can be inconsistent in some rural areas, which may affect taxpayers' ability to engage with electronic communications. One individual respondent suggested that rural communities face many of the same connectivity challenges as island communities and that older people and low-income households may be particularly affected due to their greater reliance on postal communications.

Another individual respondent, however, suggested that because post can take longer to reach island communities, electronic communications such as email and SMS messages may offer benefits in some circumstances.

Mitigating impacts

One professional body emphasised the importance of a mixed-channel approach to communications to ensure continued accessibility for rural communities. The organisation also highlighted the need to consider connectivity challenges in the design of any future communications framework.

27. Are you aware of any examples of how the proposals set out in this consultation may impact, positively or negatively, on consumers in Scotland?

Of those who answered this question quantitatively, the breakdown of views was as follows:

Accessibility, inclusion, and consumer impact

Most respondents did not identify specific impacts on consumers. Those who did generally focused on accessibility and the potential consequences of missed communications.

One individual respondent suggested that increased reliance on electronic communications could result in consumers missing important notices, leading to stress, confusion, and missed deadlines. The respondent considered that these risks may be particularly significant for vulnerable consumers and those who experience difficulties accessing or managing digital communications.

It was noted by one professional body that consumers could benefit from the speed and convenience of digital communications. However, it also highlighted risks associated with missed communications and security concerns, emphasising the need for a secure, well-supported framework that enables effective two-way communication.