ISO Tax Stamp Standard: Four Years and Counting

The Tax Stamp and Traceability Forum™ (TSTF) was an ideal gathering to learn how ISO 22382:2018, the international tax stamp standard, is being used. It gave the opportunity to hear revenue agencies’ and tax stamp suppliers’ attitude to the standard four years after it was published.

It was reassuring to learn that the overall attitude is that 22382 is a valuable and helpful tool, but it also revealed some misunderstanding of its aim, which is fundamentally ‘to assist tax authorities… by implementing new, or improving existing, excise tax stamps and associated issuance systems (by providing) guidance for tax stamp procurement, construction, security, issuance, and examination,’ as stated in the standard.

The guidance offered by 22382 to tax authorities first addresses the consultation and procurement procedures that should be followed in sourcing tax stamps, including drafting a request for information (RFI), followed by a request for proposal (RFP).

To help in creating these documents, the standard guides authorities on the functions of a stamp and stresses that the procedure should be open and transparent. It also explains that authorities should monitor and assess the performance of their issued tax stamps, so they are ready to improve their systems, or the stamps themselves, in the event that they are compromised.

The standard provides information on the construction and security features of tax stamps, including a discussion of direct marking methods, so that authorities can assess the characteristics and features they need in their stamps, which, in turn, influence the drafting of the RFP.

It would be inappropriate to have a compliance standard for public agencies, as this requires significant spending on inspection and audit in order to be certified as complying with the standard. That is why 22382 is a guidance standard.

But is there a way, short of certification under a compliance standard, of encouraging and supporting revenue agencies to operate within the standard’s guidelines? Perhaps a short course (online or at the next TSTF), or a series of seminars…

An intriguing suggestion from TSTF was that there should be a compliance standard for tax stamp suppliers. This begs the question of whether and how tax stamps are a special sub-set of secured documents that require a dedicated standard.

There are already standards for security document printers – in particular ISO 14298 (management of security printing processes) and ANSI/NASPO Security Management Standard 2015. ISO 22382 encourages tax authorities to ensure that their suppliers are certified under such standards or are otherwise recognised as a security printer (eg. a state banknote printer). Would it benefit suppliers and tax stamp issuers if there were a similar but specific compliance standard for tax stamp producers?

This question is pertinent now because ISO 22382 will be due for review in 2023, in accordance with ISO standard practice to revisit its standards every five years. There are two stages in this review process: 

• Firstly, ISO asks its member national standards bodies (NSBs) whether 22382 has been an important standard in their country; a minimum of five NSBs are required to respond positively in order to move to: 

• Secondly, asking the technical committee that drafted 22382 to review whether the standard can continue as is or whether it needs updating or otherwise changing.

If fewer than five NSBs support continuing with the standard, then ISO will withdraw it. So, whether you are a supplier or a revenue agency, please contact your NSB to tell them that this is an important standard – so as to ensure they respond positively when contacted by ISO next year.

Please contact me – Ian Lancaster, [email protected] – if you have any questions or would like to discuss any aspect of ISO 22382 and the forthcoming review.

Ian Lancaster is a former member of the International Organisation for Standards Technical Committee for Security and Resilience. He was a key contributor to ISO 12931 (authentication solutions) and 14298 (management of security printing), before becoming project leader for ISO 22382.