VATF35550 - What to consider prior to determining whether to use an intervention: making and issuing a Notice of Direction: failure to comply with the direction: reasonable excuse
The taxable person will not be liable to a penalty if they can establish that they had a reasonable excuse for their non-compliance. Reliance on a third party (e.g. to complete the records) is not acceptable as a reasonable excuse, as per Section 71 of the VATA.