Midnight at 100PS

September 8, 2014

Imagine the scene: it’s eleven thirty pm and the clock is ticking down towards midnight at 100 Parliament Street.  A crack team of HMRC and HMT civil servants are clustered around a single computer terminal, the sickly light the only source of illumination in the vast emptiness of their cavernous shared workspace (where, in daylight, a hundred drones compete for every 65 chairs).  Someone seated at the terminal constantly hits the “refresh” button, while another holds a stopwatch, and their colleagues’ gazes flick nervously between the two.  At 11.42 they start to make eye contact with each other, the light of hope dawning in their eyes.  At 11.43 there are some fingers crossed.  At 11.44 someone begins a lugubrious countdown and gradually the rest of them join in: ten… nine… eight… seven… six… Five!  Four!   THREE!   TWO!!  ONE!!!  11.45 pm everyone!  The Consultation into the New Employee shareholding vehicle is now CLOSED!

Champagne is opened.  Someone hits refresh for one last time and the whole crowd erupts: LOOK AT THAT! THIS LOSER SENT IN HIS RESPONSE AT 11.47 BWA HA HA HA HA…

Well of course it’s nonsense!  What happens in real life is you set the date for your consultation to close, you hear nothing much till the actual day, and then they all tumble in at once, some before midnight, some after, and you pick them up when you come in the next morning.  And, yes, including the ones sent hopefully at 4.30am and, if you’re feeling generous, the ones that came in half an hour after you did but before you’d finished reading the rest of them.

Nothing hangs on a consultation deadline, not to the degree of precision that requires a countdown anyway.  You need the responses to be sent so that you have time to read them and consider what’s said before you have to commit to any further action.  You might have Parliamentary and other deadlines to meet, but you know your consultation guidelines and you allow as much time as you can to give the participants giving you valuable feedback some reasonable chance of considering your proposals at leisure.  What you don’t – ever, in my experience – do, is to cut off people whose response is signed off five minutes late.

So why the devil has gov.uk started giving deadlines with actual time limits – 5pm, 11.45 pm, 12.00am – on the open consultations?  What will actually happen if I send in my response to the consultation into legislating ESC D33 at 3.31pm rather than at 3.29?  As our younger netizens say, WTF, gov.uk?

Here’s the list:

9 September 2014 5.00pm VAT: Prompt Payment Discounts

9 September 2014 11.45pm Employee benefits and expenses: exemption for paid or reimbursed expenses

9 September 2014 11.45pm Employee benefits and expenses: abolition of the £8,500 threshold for lower paid employment and form P9D

9 September 2014 11.45pm Employee benefits and expenses: real time collection of tax on benefits in kind and expenses through voluntary payrolling

9 September 2014 11.45pm Employee benefits and expenses: trivial benefits exemption

12 September 2014 11.45pm Stamp Duty Land Tax rules for property investment funds

15 September 2014 3.30pm Legislating Extra Statutory Concession D33

16 September 2014 5.00pm Annual Tax on Enveloped Dwellings: reducing the administrative burden for business

19 September 2014 5.00pm Landfill tax – liability of waste ‘fines’

19 September 2014 5.00pm VAT relief on substantially and permanently adapted motor vehicles for disabled wheelchair users

19 September 2014 5.00pm Sharing and publishing export data for public benefit

22 September 2014 5.00pm Improving the operation of the Construction Industry Scheme (CIS)

10 October 2014 5.00pm Office of Tax Simplification review of unapproved share schemes: marketable security

10 October 2014 11.45pm New Employee shareholding vehicle

15 October 2014 12.00am Inheritance Tax: exemption for emergency service personnel

16 October 2014 5.00pm Internationally mobile employees and earnings related securities

22 October 2014 9.30am implementing agreements under the global standard on automatic exchange of information

23 October 9.30am Strengthening the Tax Avoidance Disclosure Regimes

31 October 2014 5pm Tackling offshore tax evasion: Strengthening civil deterrents

31 October 2014 5pm Tackling offshore tax evasion: A new criminal offence

Hmmm… looks like a busy day tomorrow.


[Note: edited 9th September to reflect the fact there are four consultations closing at 11.45pm tonight and not 3: I had misread the Trivial Benefits closure date as 19th and not 9th.  Sorry!]


  1. Hi. I work on GOV.UK and know a bit about the background to this.

    First of all, thanks for writing this. You’re right that a consultation ending at 3:30pm feels a bit weird, and after all, what difference could it make if someone gave feedback at 3:31pm rather than 2:29.

    To answer your question, it would be up to the organisation running the consultation to decide what to do with any responses that arrive a few minutes after the published deadline. I doubt they’d mind and I’d expect common sense to prevail. The purpose of the closing date and time is to be clear with people when it ends. All that changes on GOV.UK is the ‘Ways to respond’ section is no longer shown, and the summary at the top changes from ‘This consultation closes at…’ to ‘This consultation ran from… to…’.

    We currently give organisations the ability to decide when a consultation will end. Consultations do have to end at *some* point and some organisations wanted the ability to specify a closing time other than midnight. We actually introduced a feature allowing admins to pick the time (down to quarter-of-an-hour granularity) in response to requests from users in government organisations, and because we learned from an example where not being clear about the closing time had confused and frustrated users. Consultations are important, and we obviously want to make things to be as simple and clear for people as we can.

    You’ve found some good counter examples, but usually organisations don’t pick arbitrary times like 3:30pm. Most consultations generally end at midnight or 11:45pm, a few at 5:00pm and a tiny handful at other times. I doubt that organisations publishing their consultations on GOV.UK pick the time lightly.

    There’s probably more we can do to help people here, especially in making midnight less ambiguous. (I’ve seen organisations hesitant to use midnight because they worry people won’t know if midnight on the 3rd of the month means the last moment of the 2nd rather than the last moment of the 3rd.) If I had to guess, I’d imagine that’s why many consultations end up with a deadline of 23:45.

    As with everything on GOV.UK, I’d like to do more research on this to see if there are more things we can to make things clearer and simpler for users and organisations.

    • Hard to see why you’d need quarter-hour granularity. It’s an interesting example of organisations wanting a feature which actually makes life harder for the end-user (those trying to respond to consultations). Specifying that midnight means when the little hand meets the big hand at the END of the day might have been a better solution?

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