Many employers who bring foreign staff into the UK fail to fulfil their reporting requirements to the standard expected by HMRC. This is accompanied by a conviction that, in a difficult area, employers can only do so much and if that isn’t enough they will take their chances. In response, HMRC has developed a sophisticated system of risk assessment, which is not necessarily limited to high risk employers. For those willing to engage, HMRC is open to dialogue. Against those who don’t, it may deploy its arsenal of compliance and penalty powers.