As a first step, qualifying taxpayers had to notify HMRC by 14 June 2012 of their intention to make a disclosure by completing an online notification form. The deadline for online traders to make a disclosure together with an arrangement to make payment of all tax, interest and penalties due must be made by 14 September 2012.

Making a disclosure using the e-Markets Disclosure Facility can significantly reduce the amount of penalties due and should avoid the possibility of criminal investigations taking place. Most disclosures will be subject to a maximum penalty rate of up to 10%.