HMRC Personal Liability Notice
A Personal Liability Notice, or PLN, is a notice HMRC can issue to make a company director or officer personally liable for certain unpaid National Insurance contributions, where the failure to pay was attributable to that person's neglect or fraud. It is one of the relatively few ways a company tax debt can become a personal debt, so it should never be ignored. HMRC; Social Security Administration Act 1992
- What it is
- A notice making a director personally liable for some unpaid NIC
- When
- Where non-payment was due to the director's neglect or fraud
- Can you challenge it?
- Yes, on the amount or whether the test is met, within time limits
- Do not
- Ignore it; a PLN turns a company debt into a personal one
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A rare bridge from company to personal debt
Most company tax cannot be passed to directors, but a PLN can. It is closely linked to PAYE and NIC arrears: PLNs are most associated with situations where National Insurance deducted from wages was not paid over to HMRC and the director was responsible for that decision.
Receiving a PLN does not automatically mean you must pay, because there are grounds to challenge one. If you receive one, take advice promptly from a Licensed Insolvency Practitioner or specialist adviser about challenging it or dealing with it as part of the wider position.
Related data
Our HMRC tax debt figures: The enforcement backdrop: how much tax debt HMRC is carrying. Every page on our data hub names its official source.
Where to go from here
- If you decide to speak to a Licensed Insolvency Practitioner, choose your own: our practitioner directory lists every practitioner on the official Insolvency Service register, and how to choose an insolvency practitioner explains what to ask. Always confirm their entry on the official register before you instruct anyone.
Common questions
Can I appeal a Personal Liability Notice?
Yes. You can challenge the amount or whether the neglect or fraud test is met, but there are strict time limits, so take advice as soon as you receive one.
What law lets HMRC issue a Personal Liability Notice?
Section 121C of the Social Security Administration Act 1992. It applies where a company has not paid National Insurance contributions on time and the failure appears to HMRC to be "attributable to fraud or neglect" by one or more people who were officers of the company at the time. HMRC can then serve a notice on each of those officers asking them to pay a sum towards the unpaid contributions, plus interest. If more than one officer is to blame, each is asked for a share based on how much they were to blame. Anything an officer pays comes off what the company owes (Social Security Administration Act 1992, s121C, checked 1 November 2026).
Can HMRC make a director personally liable for company tax?
Usually not, but there are two exceptions. The first is the Personal Liability Notice on this page, for some unpaid National Insurance. The second is a joint and several liability notice, which HMRC can give to "directors, shadow directors and certain other individuals connected to a company". It "will make the individuals jointly and severally liable for amounts the company owes to HMRC". It applies where the company is in, or at serious risk of, an insolvency procedure and has been involved in tax avoidance or evasion, or in repeated insolvency (gov.uk overview). For repeated insolvency, the conditions include links to at least 2 insolvent companies in the last 5 years with unpaid tax "of more than £10,000 that is more than 50% of the total amount of those companies' liabilities to their unsecured creditors" (gov.uk, repeated insolvency). HMRC says the rules are "narrowly targeted" and that most companies become insolvent "because they have genuine financial difficulties". If you get a notice, HMRC offers a review, and you have 30 days to accept it. Both gov.uk pages checked 1 November 2026. If the company owes tax now, see HMRC debt collectors and Time to Pay arrangements.