HM Revenue and Customs

7. Mr D complains that HMRC failed to record national insurance contributions he made between 1978 to 1999. He also complains it did not properly consider the evidence he provided and did not keep records that he believes it should have.

8. Mr D tells us that as a result of not recording his contributions, his state pension is reduced, and this has caused him financial hardship and distress. He has found the failure to see the proof in his evidence and the fact it did not keep historic records to be frustrating.

9. Mr D would like HMRC to update its records so that he has an entitlement to a full pension. He also wants it to backdate the amount of pension he has lost to date.

10. National Insurance (NI) contributions were paid to the Government either through an employer or directly by the person if, for example, they were self-employed.

11. To get a full state pension, a certain number of ‘qualifying years’ of NI contributions is required. This varies depending on when you started paying contributions (pre or post 2016). If you do not pay the full qualifying amount, you get a proportion based on the number of years you have paid. The Department for Work and Pensions (DWP) manage the calculation and payment of the state pension.

12. For context, between July 1948 and April 1992 Class 2 and 3 NI contributions were made by buying special adhesive stamps from the Post Office and affixing them to official National Insurance Cards (CF1).

13. A Class 2 contribution was one made by a self-employed person. Class 3 contributions were voluntary contributions where a person, who was not employed might want to increase their pension entitlement (up to a certain maximum). Class 4 contributions are based on the profit earned in self-employment, but these do not contribute to the state pension.

14. Only by affixing the stamps to a valid card and cancelling them by writing the date across the stamp did they become a paid contribution. These cards had to be exchanged for new ones on an annual basis at the appropriate government office. The rates of contributions payable also changed each year.

15. From 1992/93 the only methods of payment of these contributions available were either by Direct Debit (introduced in 1975) or quarterly billing.

16. Mr D contacted HMRC in July 2023 to ask it about missing NI contributions on his online record. He provided evidence to HMRC from the 1980s and 1990s of communications from the Inland Revenue (IR - the predecessor to HMRC) to his accountant and a copy of an NI stamp to the value of £3.75.

17. HMRC responded in February 2024 and explained that there was no record of stamp cards for the years 1978/9 to 1986/7. It also added that its records showed no registered address in the NI database for Mr D between 1987/88 to 1993/94.

18. Mr B responded the following month to say he disagreed that he had not bought stamps and sent in stamp cards. He also challenged the lack of address for him as he had letters from the IR showing his correct address.

19. HMRC replied in September 2024 and acknowledged that Mr B disagreed but that without evidence he paid the contributions his record could not be changed. It also added that it could not be sure why the IR had his address but the contributions agency that handled NI did not.

20. In September 2024, Mr D escalated the complaint to Tier 2 of the process and in October 2024 HMRC responded to say it had reviewed the decision, agreed with it, and had nothing more to add.

21. Mr D was directed to the Adjudicator’s Office (AO) if he wished to escalate his complaint. He did so and in May 2025 the AO wrote to Mr D to say that based on the evidence it had seen it could not ask HMRC to overturn its decision not to change his NI record.

22. Mr D then brought his complaint to our Office in August 2025.

Contributions and evidence

24. Mr D tells us that he made the contributions and HMRC is at fault for not recording them. He said it ignored the evidence he provided and should have had more evidence in its files.

25. HMRC told us that the evidence shows Mr D did not submit his NI stamp cards for the period in question. It also says it took account of the evidence he provided and could not find any further evidence on its system.

26. Mr D tells us that when he tried checking his entitlement online prior to retirement age, the system told him ‘under review’ for several years. He wrote to HMRC in July 2023 to try to resolve the matter and when he could not be brought a complaint to HMRC in March 2024.

27. On its website, HMRC advises customers who wish to complain that:

HMRC will not treat you differently to anyone else because you’ve made a complaint. They will handle your complaint fairly, confidentially and investigate the issues thoroughly.

28. This is supported in its complaint handling guidance where it says staff should:

Ensure that you carry out a thorough examination of the case.

29. We can see in its Tier 1 and Tier 2 complaint responses that HMRC considered the evidence Mr D provided. It said, in its Tier 2 response of September 2024 that it did not see the copy of the NI stamp that he sent in however that would not provide evidence that he added it to a card and submitted it.

30. HMRC told Mr D that there was no evidence on its system he had submitted stamp cards for the period he claimed he did. It also told him that between 1978/79 to 1986/87 it had sent him notices to say it had not received them. It added that because it did not have an address for him on the NI system between 1987/88 to 1993/94, it was unable to send him notices to tell him it had not received stamp cards for that period.

31. We have seen evidence, in the form of screenshots of the HMRC system that shows examples of the above. The first shows that a ‘no card’ notice was issued in 1980 and that one could not be issued in 1987 as there was no address recorded on Mr D’s NI account.

32. We can appreciate that Mr D believes the evidence he provided supports his position that he was making NI payments to the IR. Some of this is assessments that include reference to Class 4 NI contributions. The AO explained to Mr D that those contributions do not count towards a state pension. The HMRC NI Manual confirms that Class 4 contributions do not count towards a state pension.

33. Mr D asked us to look at a letter from the IR to his accountant in May 1992 in which it says, ‘since the accounts for the earlier years have already been agreed…’. He says this is evidence that at that point he had clearly been making his NI payments as his accounts ‘were agreed.’

34. We asked HMRC about this and it told us that this would have been referring only to income tax accounts and not NI contributions which would be handled separately. It explained that up until 1999, the Contributions Agency (which reported to the Department of Social Security) was responsible for collecting and recording NI.

35. We have confirmed this is the case by looking into the Government archives where reference to that is found in the Social Security Contributions (Transfer of Functions, etc.) Act 1999. This explains what that function was and how it was going to be absorbed in the IR that year.

36. Mr D said he recalled making a payment of around £330 to the IR which he believes was for NI contributions. HMRC said there was no record of that, and it was likely a payment towards income tax he owed but it could not be certain. Like HMRC, we cannot see any evidence of such a payment in the evidence he provided.

37. Mr D told us that HMRC must still have records of communications between it (or the IR as it was then) and his accountant. Both HMRC and the AO have told us they have not found any additional evidence from that period, and it has likely been disposed of, in line with its Retention Policy.

38. That Policy is based on the Data Protection Act 2018 and subsequent General Data Protection Regulations 2018 (GDPR). It explains that most data are kept for six years and only legally required data is kept longer. It told us that communications older than six years relating to tax returns would have been deleted under that policy as it was ‘not be retained for longer than is necessary for its lawful purpose.’

39. In its complaint response of September 2024, HMRC confirmed that it had not found any other details relating to the matter and acknowledged Mr D’s disappointment with the previous response of September 2024.

40. We have seen that HMRC considered Mr D’s evidence and examined its own systems to provide evidence of why it had no record of NI contributions. We can see it acted in line with its Guidance by carrying out a thorough examination of the case. It acted in line with its data retention policies when it deleted records it no longer had lawful reason to keep.

41. We acknowledge that Mr D has and is drawing a pension that is less than he expected it to be. This is clearly difficult time for him and his wife and is causing distress, and we are sorry to hear that is the case. We can appreciate that he planned for a different situation.

42. We also know from what he has told us that he has been very unwell, and we hope that he is on the road to good health again.

43. Based on the above, we find HMRC acted in line with its guidance in how it handled his complaint and his data. We therefore will take no further action.

1. We have carefully considered Mr D’s complaint about HM Revenue and Customs (HMRC). We can see that he is unhappy with HMRC’s response to his concerns about his National Insurance contributions. We are sorry to read these events have caused such distress.

2. Having considered the evidence available to us, we can see that HMRC has considered Mr D’s evidence in its investigation of his complaint to it. This is in line with HMRC’s Complaint Handling guidance.

3. We have also seen that HMRC has reviewed its own records and explained to Mr D why there is no record of NI contributions between 1978 to 1999. This is in line with its Complaint Handling guidance.

4. It has also acted in line with it data retention policies when it deleted correspondence that it could not lawfully keep.

5. We will not take any further action on Mr D’s complaint.

6. We appreciate Mr D feels strongly about the complaint, and our statement below sets out the reasons for our decision.