In a bold and unusual move, the UK government has launched a time-limited “no questions asked” voluntary repayment scheme for individuals and businesses that received pandemic support payments or grants they were not entitled to. The window opened on 12 September 2025 and runs until the end of December 2025.
This is a “use it or lose it” opportunity: if you come forward within the window, you can repay the funds without facing immediate enforcement action. But once the window closes, the government warns, you may be exposed to tougher sanctions, investigations and legal consequences.
Why now? The case for an amnesty
The pandemic support programmes were extensive, varied, and introduced under extreme time pressure. As a result, millions of payments were made via furlough (CJRS), self-employment grants (SEISS), business loans (such as Bounce Back Loans, CBILS), local authority grants, and more.
Because of that urgency, design flaws, misunderstanding of eligibility, or honest mistakes, some recipients may have ended up with funds they were not legally entitled to. In other cases, deliberate fraud or abuse has been identified.
The government estimates that over £10 billion has been lost to COVID-related fraud, waste, and overpayments, yet only about £1.54 billion has so far been recovered through existing efforts.
By offering a “voluntary repayment window,” the government hopes to recover more funds more easily, reduce the administrative and legal burden of enforcement, and incentivise individuals and businesses to come forward voluntarily.
What the scheme covers
The voluntary repayment scheme is broad in scope. It covers all types of COVID-era support, including (but not limited to):
- Loans (e.g. Bounce Back Loans, CBILS)
- Furlough payments (CJRS / Job Retention Scheme)
- Self-employment support (SEISS)
- Other related tax, social security, or benefit payments tied to COVID support
In short: if you got COVID support in any capacity, this scheme may apply to you.
How to participate (in broad strokes)
Here’s how the process works (or is expected to work), as per official guidance and commentary:
1. Decide whether repayment is needed
Review your claims and support you received. If you believe you received more than you were legally entitled to, or funds you no longer need, you may choose to repay.
2. Engage with the appropriate authority
- For grants and tax/benefit schemes (like SEISS, CJRS), you’ll likely use an HMRC portal or GOV.UK service.
- For loans (e.g. Bounce Back Loans), you’ll typically liaise with the lender (bank) to initiate repayment.
- If a scheme is not covered by the published channels, the government says you may email — for example, voluntaryrepayment@cabinetoffice.gov.uk — with details to get direction.
3. Provide necessary details
Expect to submit scheme reference, dates, amounts, your identifier (e.g. UTR, company number) and possibly explanation of why repayment is being made.
4. Make the payment
Use standard payment methods (bank transfer, etc.) as directed by the authority or lender. The government seeks to make the process as simple as possible.
5. Receive formal closure / acknowledgement
Once paid, the expectation is that the matter is closed — no further enforcement over that particular overpayment. But note: repayment through this scheme does not guarantee immunity from action in other respects (e.g. if misconduct or fraud is involved).
Risks of not taking part — and what happens after December 2025
The government is explicit: this is the last lenient window. After December 2025, the voluntary route closes and tougher measures will come into play.
Possible consequences include:
- Penalties, interest, and legal claims: in some cases, overpayments may be subject to interest or penalties beyond the base amount.
- Criminal prosecution or disqualification: particularly for those who acted intentionally or dishonestly, directors may face disqualification, compensation orders, or even prison.
- Reputational damage: non-repayment or enforcement actions publicly exposed may harm personal or corporate reputation.
In the context of insolvency, the Insolvency Practitioners Association cautions that voluntary repayment does not automatically shield directors from enforcement — misconduct must still be reported in normal channels.
Not acting before the window closes could leave you vulnerable to all of the above with less recourse and more pressure.
What to do now
- Act early: Don’t wait until December. The scheme may not specify an exact cut-off day; sooner is safer.
- Conduct a claims review: Go back over all pandemic-era support you received (2020–2022) and check eligibility, documentation, and whether any amounts should be returned.
- Seek professional advice: For businesses, this is especially important — accounting, legal, tax and insolvency advice can help manage the risk and process.
- Document your reasoning: If you choose to repay, keep clear records of your claim, your calculations, and your decision-making. That may help defend against challenges later.
- Be candid where possible: Using the voluntary window shows good faith — in case there are ambiguous or borderline payments, demonstrating your intent to comply may help.
- Monitor government updates: As the scheme is new, guidance, FAQs, and procedural details may evolve. The government is likely to publish updates on GOV.UK.
Final thoughts
This voluntary repayment window is a sharp pivot in the UK’s COVID recovery strategy. It signals that the government is ready to move from emergency relief to scrutiny and enforcement. For many, it offers a last chance to “do the right thing” and settle outstanding liabilities on manageable terms.
That said, the window is short. If you're unsure whether you need to repay, or how to do so, the prudent move is to act early, get professional advice, and engage while the terms are still favourable.
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