Attending a government webinar to stay informed about National Minimum Wage compliance seems like responsible business practice. Yet several employers have recently found themselves in an uncomfortable position: a few weeks after joining an HMRC NMW webinar, a Voluntary Declaration Form lands in their inbox.

For many, this wasn’t expected. They’d simply logged in to listen and learn, often using their company email address, and suddenly they’re being asked to declare potential errors. It’s left business owners and HR teams asking some very reasonable questions about what this means and how they should respond.

The Dilemma of "Voluntary" Disclosure

The first question many face is straightforward but tricky, what if you’ve reviewed your practices based on the webinar content and genuinely believe there aren’t any errors to declare? Should you still respond to HMRC to confirm this, or is silence acceptable?

There’s also the concern about what happens if you choose not to complete the form at all.

Does leaving it unanswered increase your risk of a future HMRC investigation? Nobody wants their attempt to stay informed to inadvertently paint a target on their business.

The Scope Problem

Another valid concern relates to the scope of these webinars. HMRC sessions often focus on specific NMW risk areas, perhaps salary sacrifice schemes, accommodation offset rules, or working time calculations. But National Minimum Wage compliance is complex, with multiple potential pitfalls. What about the risk areas that weren’t covered in that particular session? Are you expected to review your entire NMW compliance picture, or just the topic discussed?

This creates genuine uncertainty. An employer might attend a webinar on uniform deductions, find their practices are sound in that area, but remain unaware of issues elsewhere, perhaps around travel time or unpaid training.

When Junior Staff Attend

Perhaps most frustrating is the situation where a junior team member attended purely for professional development. An assistant or coordinator might have joined the webinar to upskill and better understand employment law, yet this could still trigger the same compliance follow-up for the business. It feels disproportionate when the attendance was about learning, not because the company suspected problems.

A Word of Caution

None of this is to discourage employers from engaging with HMRC’s educational resources, they can be genuinely valuable. However, it’s a useful reminder that any follow-up communication, particularly those requesting information or declarations, should be approached thoughtfully and with proper context.

Before responding to any voluntary declaration form, businesses should:

• Understand exactly what they’re being asked to declare and why
• Consider the scope of their review carefully 
• Seek professional advice if uncertain about their obligations
• Be aware that "voluntary" disclosure isn’t always without consequences

The tension here is real, employers want to stay informed and compliant, but understandably don’t want routine learning to trigger unintended compliance procedures. HMRC’s intention may be to encourage self-correction and education, but the approach can feel like a penalty for engagement.

If you’ve received one of these forms following a webinar, take time to understand your position fully before responding. Professional guidance can help you decide when and how to reply, ensuring you meet your obligations without inadvertently creating problems that don’t exist.