COVID voluntary repayment scheme launched – last chance to resolve liability before tougher sanctions apply

On 12 September 2025, the UK Government launched a time-limited COVID repayment window, allowing individuals and businesses to voluntarily repay financial support received during the COVID-19 pandemic, with no questions asked.

The window closes in December 2025, after the deadline, tougher sanctions will be applied, including civil and criminal investigations, director disqualification and formal enforcement proceedings.  This initiative forms part of the government's broader efforts to recover over £10bn lost to COVID-related fraud and signals a clear shift towards stricter enforcement. 

Who can use the voluntary repayment scheme?

The scheme can be used by anyone who received financial support during the pandemic, including through the Coronavirus Job Retention Scheme, Bounce Back Loan Scheme, Self-Employment Income Support Scheme, Coronavirus Business Interruption Loan Scheme or sector-specific funding. It is particularly relevant for individuals or businesses that may have misunderstood the eligibility criteria at the time, or who now believe that some of the support was wrongly claimed or retained. Company directors should also take note, especially where support was accessed on behalf of their business.

Why this matters 

This window offers a critical opportunity to proactively manage and reduce risk. Failure to act before the December 2025 deadline could result in serious consequences. From 2026 onwards, HMRC and other government bodies are expected to intensify scrutiny and enforcement efforts across all COVID-related support schemes.

Those businesses and individuals found to have made improper claims may face civil or criminal investigations, recovery actions, director disqualification and potential personal liability for directors. Beyond the legal implications, there is also a significant risk of reputational harm, particularly if enforcement actions become public.

What you should do now

• Review all COVID-related support received - consider the full range of schemes accessed by your business or personally.
• Revisit the eligibility criteria - assess whether claims were validly made at the time based on the original criteria.
• Quantify any potential exposure – calculate how much might need to be repaid, and what the cost of inaction could be.
• Seek early legal and tax advice - if you are unsure, professional input can help frame your options and prepare your position.
• Prepare for disclosure - if repayment is appropriate, ensure full disclosure is made and the process is handled correctly and documented clearly.

How we can help

This window is likely to be the final opportunity to come forward on your own terms, without sanction. In our experience, early action and voluntary engagement tend to result in significantly better outcomes, both financially and reputationally.

If you are concerned about any COVID-related claims made by you or your business, please get in touch with our team.

We can assist by reviewing the eligibility of claims made under COVID support schemes to help determine whether they were appropriate based on the original criteria. If repayment is necessary, we can prepare and submit voluntary disclosures on your behalf and manage all communications with the relevant authorities to ensure the process is handled correctly and efficiently. If you are already facing investigation or enforcement action, we can advise and represent you throughout the process.