MoU on Identifying Fraud in Cultural Recovery Fund Applications
Summary
HMRC, DCMS, and Arts Council England have published a Memorandum of Understanding (MoU) to identify potential fraud in Cultural Recovery Fund applications submitted during the COVID-19 pandemic. The MoU facilitates data sharing to detect falsified earnings declared by applicants, with potential outcomes including repayment of grants and criminal charges.
What changed
This Memorandum of Understanding (MoU) between HM Revenue & Customs (HMRC), the Department for Culture, Media & Sport (DCMS), and Arts Council England (ACE) establishes a framework for identifying potential fraud in applications for the Cultural Recovery Fund (CRF), which was awarded during the COVID-19 pandemic. The agreement, effective in 2025, allows HMRC to share data with DCMS to detect instances where organizations may have declared falsified earnings to receive larger grants. The primary goal is to identify and recover misused funds, with potential consequences including repayment of the grant and possible criminal charges.
Regulated entities that applied for the CRF and may have overstated their earnings should be aware of this data-sharing initiative. If fraud is suspected, DCMS will refer cases to ACE for investigation, which could lead to requests for repayment of funds and potential law enforcement involvement. This initiative also aims to identify control gaps in grant schemes and demonstrates a commitment to investigating the abuse of COVID-19 support schemes. While not a direct compliance requirement for entities not involved in fraud, it signals increased scrutiny on past grant applications and may inform future risk assessments for grant programs.
What to do next
- Review Cultural Recovery Fund application declarations for accuracy.
- Be prepared to provide documentation supporting declared earnings if contacted by DCMS or ACE.
- Consult legal counsel if potential discrepancies are identified in past applications.
Penalties
Repayment of grant and possible criminal charges.
Source document (simplified)
Transparency data
Potential fraud applications to the Cultural Recovery Fund 2025
This MoU for supporting the identifying of potential fraudulent company applications to the Cultural Recovery Fund was agreed and put in place in 2025.
From: HM Revenue & Customs, Department for Culture, Media and Sport and Arts Council England Published 19 March 2026 Get emails about this page
Documents
Memorandum of Understanding: Supporting the identifying of potential fraudulent company applications to the Cultural Recovery Fund
Ref: RIS MOU 2025
HTML
Details
This agreement is published as part of the Code of Practice for public authorities disclosing information under chapters 1, 3 and 4 (Public Service Delivery, Debt and Fraud) of part 5 of the Digital Economy Act 2017.
The purpose of this data share is for HM Revenue and Customs (HMRC) to help the Department for Culture, Media & Sport (DCMS) detect fraud against organisations and businesses who have submitted applications for a grant during the COVID-19 pandemic.
The Culture Recovery Fund (CRF) awarded grants to organisations based on a number of criteria, such as cultural significance, however in most cases turnover of the applicant organisation was an important variable and one of the key determinant factors in the size of the award.
The data share will seek to identify those organisations and businesses who applied for a CRF grant and had declared falsified earnings in order to receive more money with the potential outcome of repayment of grant and possible criminal charges. If fraud is suspected, then DCMS will seek to refer the case to Arts Council England (ACE) for their further investigation. This may then lead to ACE requesting a copy of the company tax return from the applicant and should this show no legitimate explanation for the discrepancy then they would issue a request for repayment of the funds and consider law enforcement involvement as appropriate.
Benefits of this data share are as follows:
- identification of fraud which can then be investigated and recovered
- identification of control gaps in ongoing and future grant schemes
- serves as a statistically valid fraud measurement exercise for the purpose of assessing overstatement of need/turnover fraud allowing DCMS to inform risk appetite and wider corporate governance
- if successful may allow for future HMRC data sharing to mitigate future risks of fraud
- demonstrates government commitment to investigating potential abuse of COVID-19 support schemes of which there is a significant public interest There are no direct benefits to HMRC other than to support DCMS in their aim of identifying fraudulent company applications to the Cultural Recovery Fund.
Updates to this page
Published 19 March 2026
Sign up for emails or print this page
Get emails about this page Print this page
Named provisions
Related changes
Source
Classification
Who this affects
Taxonomy
Browse Categories
Get Tax alerts
Weekly digest. AI-summarized, no noise.
Free. Unsubscribe anytime.
Get alerts for this source
We'll email you when UK HMRC Publications & Guidance publishes new changes.