Reporting requirements for employment intermediaries

What is an employment intermediaries report?

As an agency, if you supply temporary workers to an end client and are not paying those workers on a PAYE basis, you will be required to submit an employment intermediaries report. This means that you have report on any worker who is paid through an umbrella company, CIS contracting company, personal service company, or similar third party entity. More information about your obligations as an intermediary.

Why were these rules introduced?

HMRC identified consistent evidence of intermediaries facilitating self-employment and supplying UK-based workers from offshore locations. As a result, new legislation was introduced requiring ALL intermediaries, including recruitment agencies, to provide details of the workers they supply, and the payments they have made in respect of those workers, on a quarterly basis.

As a recruitment business, am I definitely an intermediary?

Yes, if you make arrangements for an individual to work for a third party or pay for work done for a third party then you are an intermediary under this legislation.

Do I need to register for the intermediary’s report?

You will need a Government Gateway account. If you don’t already have a Government Gateway account, you can create one when submitting your first report. You will also need your Employer PAYE reference and Accounts Office reference.

How do I submit a report?

You will need to use the official HMRC template, which is available to download here. Once you have completed it, you will need to log in at this webpage with your Government Gateway details to upload it.

What are the reporting periods and deadlines for employee intermediary reporting?

The current reporting periods and submission deadlines are:

  • 6th January to 5th April to be submitted by 5th May
  • 6th April to the 5th July Deadline to be submitted by 5th August.
  • 6th July to the 5th October Deadline to be submitted by 5th November
  • 6th October to the 5th January Deadline to be submitted by 5th February

What happens if I forget to submit a report or if I make a mistake when submitting the report?

You will receive a fine if the report is late, incomplete, or wrong. This increases depending on the number of late reports submitted within a 12-month period. The current penalties are:

  • £250 for a 1st offence
  • £500 for a 2nd offence
  • £1,000 for any further offences within the 12-month period

If there is a pattern of non-compliance or a series of breaches, you can be fined up to £600 for every day that a report is overdue.

There is a process for appealing against penalties, the details of which are published on this webpage.

Do I need to report on my permanent placements?

No, the employment intermediaries reporting rules don’t apply to perm