Guidance

Issue 135 of Agent Update

Published 18 September 2025

© Crown copyright 2025

This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk.

Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.

This publication is available at https://www.gov.uk/government/publications/agent-update-issue-135/issue-135-of-agent-update

Technical updates and reminders

Developments and changes to legislation and allowances relating to UK tax including:

Tax

Borders and Trade

Making Tax Digital

HMRC agent services

Agent engagement

Latest updates from the partnership between HMRC and the main agent representative bodies:

Tax

Guidance for labour supply chains featuring umbrella companies — PAYE responsibilities

HMRC has published guidance on significant changes to umbrella company regulations. 

From 6 April 2026, recruitment agencies (or, in their absence, end clients) will be accountable for Pay As You Earn (PAYE) on payments to workers supplied through umbrella companies.

The guidance provides detailed information on the changes which have been designed to tackle non-compliance in the umbrella company market.

To understand implementation requirements and ensure compliance readiness, agencies and other parties in labour supply chains can register for a webinar about labour supply chains featuring umbrella companies. The webinars will be held on 7 October, 21 October and 17 November 2025.

The Employment Status Manual has also been updated to reflect these changes.

Final Reminder — UK businesses in climate change agreements to report annual tax subsidy awards to HMRC by 30 September 2025

In the previous Agent Update issue, HMRC reminded businesses about the deadline to report annual subsidy awards exceeding £100,000 from the Climate Change Levy (CCL).

If your business is part of a climate change agreement (CCA) and receives annual subsidy awards exceeding £100,000 from the Climate Change Levy (CCL), you are required to report this information to HMRC by 30 September 2025.

The subsidy reporting requirements are the:

  • reporting period — HMRC is collecting CCA subsidy award information for calendar year 2024 (1 January to 31 December 2024)

  • threshold — if your subsidy award for 2024 is over £100,000, you must complete the online form on GOV.UK by 30 September 2025

Why this is important

HMRC is required to collect data from UK businesses whose annual tax subsidy awards exceed the defined thresholds. This data will be published to promote accountability and transparency.

Action required by 30 September 2025

You will need to:

  1. Check your records — review your documentation to see if you meet the threshold requirements.

  2. Complete the online form to report Climate Change Levy subsidies — you can check when to report and how to work out your Climate Change Levy subsidy

  3. Submit this information by 30 September 2025.

If you are reporting as a VAT group, you should report the representative member’s name only and apply the threshold requirements at the group level.

If your business is registered in Northern Ireland and trades in goods or the wholesale electricity market, you will need to report your annual CCA subsidy award if it exceeds 100,000 euros, which is £84,825 when converted to British pounds. Visit GOV.UK to find more information about complying with the UK’s international obligations on subsidy control.

You don’t need to do anything else if you meet the defined threshold for calendar year 2024 and have already reported this to HMRC.

Visit GOV.UK for further details about reporting your CCA subsidies to HMRC, including how to work out your annual Climate Change Levy subsidy award and information to report to HMRC.

Contact energy.taxes@hmrc.gov.uk for any queries.

When National Insurance contributions should be paid on earnings for internationally or globally mobile employees

HMRC has updated the guidance to help employers determine when National Insurance contributions are due on earnings paid to internationally mobile employees. 

Employees are internationally mobile if they:  

  • live in the UK but work overseas
  • come from overseas for periods of work in the UK
  • are UK or overseas residents who move in and out of the UK to work
  • may work in several countries and have an employer based overseas

While earnings are generally paid at the time the work is carried out, employees may receive later payments, such as bonuses, after they are earned. For example, after leaving a job in one country and returning home or taking another role in a different country.  

The updated guidance confirms that if the employee was liable for National Insurance contributions at the time the work was carried out, they will continue to be liable for National Insurance contributions in respect of those earnings, even if they are paid later.  

First, employers should determine whether their employee was liable for National Insurance contributions at the time the work was carried out. Your clients can check how to calculate National insurance for employees working abroad and new employees coming to work from abroad , or refer to examples in the NIM33000 section of the National Insurance Manual. 

If the employee was liable for National Insurance contributions at the time the work was carried out, employers should calculate and deduct National Insurance contributions from the earnings, even if they are paid later when the employee has gone abroad.  

If the employee was not liable for National Insurance contributions at the time the work was carried out, there will be no liability to pay National Insurance contributions when the earnings are paid. 

Employers may be able to use their payroll software to work out the amount to be taken into consideration when calculating and deducting National Insurance contributions.

If your clients are unable to use their payroll software, they can find: 

Read more on how to correct National Insurance contributions on earnings for internationally or globally mobile employees in CWG2: Employer further guide to PAYE and National Insurance contributions. This includes further technical guidance on National Insurance contributions including employees coming to or leaving the UK — treatment for PAYE purposes. 

How to correct National Insurance contributions on earnings for internationally or globally mobile employees 

Where employers have considered the updated guidance in the previous article to calculate National Insurance contribution payments, they may now find that they have either over or underpaid National Insurance contributions. Agents should advise clients who are employers to use the following process.

How to correct employer returns where National Insurance contributions have been over or underpaid  

Where National Insurance contributions for internationally mobile employees have been over or underpaid, employers should be advised to make corrections through Real Time Information (RTI) going back 6 years.

Employers must make sure that relevant evidence is held to support any amendment, including:

  • a record of the employees, with their National Insurance numbers
  • the total amount and description of the relevant earnings and the amount of National Insurance contributions already paid on it
  • when the relevant earnings were paid and the period over which they were earned
  • the amount of the relevant earnings now considered to be liable to National Insurance contributions
  • the amount of employee and employer Class 1 National Insurance contributions now considered to be correct
  • the amount of National Insurance contributions now due to be paid or refunded
  • an explanation of what caused National Insurance contributions to be over or underpaid

Fix problems with running payroll: you paid your employee the wrong amount or made incorrect deductions provides guidance on how to correct a client’s return through Full Payment Submission and how to make a refund claim when employers have overpaid National Insurance contributions and are unable to amend their RTI returns.  

If your client is making a claim

In addition to the evidence required on how to correct employer returns where National Insurance contributions have been over or underpaid, you should advise them they also need to: 

  • use the reference ‘NICs refund for Internationally Mobile Employees’
  • provide the reason they cannot make the amendment through RTI

Further information on how to make a voluntary disclosure to HMRC is available. In your client’s disclosure letter use the reference ‘NICs Disclosure for Internationally Mobile Employees’.   

Large businesses with a HMRC Customer Compliance Manager (CCM) should notify them of any RTI corrections and before making any refund claims. Voluntary disclosures being made by large business customers should be sent to HMRC in line with the existing process. 

What your clients should tell their employees who wish to claim a refund where National Insurance contributions have been overpaid

Employers should be advised that where employees believe they are due a refund they must contact their employer first. If your client, as the employer, made an RTI amendment, they should repay any overpaid National Insurance contributions owed to the employee.

If your clients have not submitted an RTI amendment or applied for a refund, their employees will have to provide the following information to HMRC based on all pay periods affected:  

  • National Insurance number
  • description of the relevant earnings
  • when the relevant earnings were paid and the period over which they were earned
  • reference that this is an internationally mobile employee case where National Insurance contributions were overpaid, for example, at the time the work is carried out they were not liable to National Insurance contributions
  • the Class 1 National Insurance contributions that are being reclaimed
  • the reason their employer is not applying for the refund on their behalf

We know the refunds process is currently long and complex and are working on a digital solution to improve it.

Read more information on how to claim a National Insurance refund. 

Reserved Investor Fund new online entry and accounting period information forms

We have published two new online forms for Reserved Investor Fund (RIF) operators:

RIF Operators should use these forms when making an entry notice or submitting accounting period information to HMRC. 

The online entry notice form replaces the temporary PDF form published in March 2025.

Guidelines for Compliance — help ensuring documents filed with HMRC are correct and complete

HMRC has recently published new guidelines for help ensuring documents filed with HMRC are correct and complete.

Most customers make their best efforts when providing information to HMRC and have no cause to doubt the information they submit is correct and complete.

They can ensure the information is correct and complete by:

  • checking their records
  • reading HMRC guidance
  • if appropriate, consulting a professional advisor trained and competent for the task at hand

This publication is designed to help customers when they:

  • remain uncertain of the correct interpretation of the law after making their best efforts to resolve that uncertainty
  • are applying a novel interpretation of the law
  • are considering applying an improbable interpretation of the law

These guidelines are a practical product for customers to refer to and they:

  • explain HMRC’s view that a customer should choose an interpretation of the law that is, on balance, most likely correct
  • demonstrate the importance of all facts and views of the law being correct and complete to the best of a customer’s knowledge
  • provide recommended approach to professional advice
  • help to resolve remaining uncertainty
  • cover expectations of advisers
  • provide practical examples of legal uncertainty

They should be read alongside HMRC’s existing guidance.  

Guidelines for Compliance are part of HMRC’s ongoing commitment to publishing practical guidance to support customers. They can help you better understand what HMRC considers to be good practice. They can clarify our view in complex, widely misunderstood or new areas of the tax system.

Read more information on Guidelines for Compliance including our other publications, on GOV.UK.

Self Assessment Class 2 National Insurance contributions 

Work has been progressing to resolve an issue with Class 2 National Insurance contributions affecting some Self Assessment (SA) customers – as detailed in Issue 133 of Agent Update. 

A technical fix is scheduled for deployment over the weekend of 27 and 28 September 2025. This means that all SA302 tax calculations issued from Monday 29 September will reflect the correct Class 2 National Insurance contribution position. 

Self-employed customers who have already filed SA tax returns for 2024 to 2025 will have their records checked and, if necessary corrected, before the January 2026 payment deadline.

This will happen on a rolling basis and so we are unable to share precise timings. However, further updates will be provided as more information becomes available. Customers will receive updated SA302 tax calculations wherever corrective action has taken place. 

In instances where customers have already paid an incorrectly applied charge, we will ensure that the National Insurance position on their SA statement reflects the right amount and will adjust the amount of any further SA charge due this year. 

In the last few months, we have been made aware of 6 cases of incorrect SA302 tax calculations creating issues for self-employed customers applying for mortgages. In all 6 cases, we immediately corrected records and issued updated SA302 tax calculations.

Borders and Trade

Using ICS2 for goods movements by road and rail from Great Britain to Northern Ireland

In Agent Update issue 134, we informed you that we were exploring options to support those who would not be ready to move to Import Control System 2 (ICS2) by 1 September 2025. 

We can now confirm that, if you need more time to prepare, you will be able to submit Entry Summary (ENS) declarations through Import Control System Northern Ireland (ICSNI) for movements until 31 December 2025. However, you should continue to work with your supply chain to make sure you are ready to use ICS2 as soon as possible and no later than 31 December 2025. 

If you and your customers are already using ICS2 you should continue to do so, or if you and your customers expect to be ready to migrate to ICS2 shortly you should continue preparations and migrate as planned. 

You do not need to make ENS declarations for parcels moving to and from consumers (such as private individuals) in Northern Ireland. 

When physically moving goods from Great Britain to Northern Ireland  

Trader Support Service (TSS) users can continue to submit ENS declarations using ICSNI or the new ICS2 dataset if ready to do so. For movements from 1 January 2026, the new ICS2 dataset will become mandatory for all TSS users. 

TSS users do not need to register to use ICS2 as the TSS will do this for them.  

However, non-TSS users must register by 31 December 2025 to use the EU Shared Trader Interface (also known as the EU Customs Trader Portal) to submit safety and security declarations into ICS2. Guidance is available on GOV.UK.

Users must register to use the Import Control System 2

You do not need to do anything if you are already using ICS2 when moving goods by road (including roll-on roll-off movements) from Great Britain to Northern Ireland.  

When sending or receiving goods moving from Great Britain to Northern Ireland  

If you or your customer is a business that sends or receives goods that move from Great Britain to Northern Ireland, you should: 

  • speak with those who are physically moving your goods on your behalf, such as your haulier, freight forwarder or express operator to check whether they need to make any changes to their processes for ICS2
  • make sure that for movements arriving in Northern Ireland after 31 December 2025 your supply chain has the correct information, at the correct time, to keep your goods moving as smoothly and efficiently as possible

When sending or receiving goods moving from Great Britain to the EU 

If you or your customer moves goods from Great Britain into the EU, you may need to use ICS2 now depending on the country you are moving goods into. Visit Import Control System 2 — European Commission and read the ‘Guidance for the submission of an ENS for road and rail during the ICS2 and NCTS P6 derogation period’. This will provide a list of all ICS2 territories and the date from which ICS2 becomes mandatory for road and rail movements.

If you or your customer moves goods by transit, you will need to meet safety and security requirements for the relevant system (ICS, ICS2 or NCTS6-TSADs) of the country you are moving goods into. 

You must check with the customs authority of the ICS2 territory you’re moving goods into for details about which systems to use and any specific ICS2 processes to follow (for example, use of the Obligatory Logistics Envelope (ELO) system for movements into France). 

Read more information on:

Making Tax Digital

Get ready for Making Tax Digital for Income Tax

HMRC is hosting a series of Making Tax Digital (MTD) for Income Tax events at HMRC offices across the UK this year.

Agents and software developers are welcome to attend one of these sessions to help them prepare for when MTD for Income Tax becomes a legal requirement in April 2026.

By attending these MTD for Income tax events you will:

  • learn more about taking part in the testing phase and the additional support you will receive
  • receive hands-on guidance to sign up for testing
  • understand which clients will fall under MTD for Income Tax
  • gain clarity on MTD obligations and compatible software
  • discuss managing clients using the Agent Services Account
  • have the opportunity to ask HMRC your MTD-related questions

Registration is now open for the following events, which will each take place from 11am to 3pm:

  • Tuesday 28 October 2025 — Leeds
  • Tuesday 11 November 2025 — Edinburgh
  • Wednesday 19 November 2025 — Belfast

Spaces are limited so if you are interested in attending, please email mailboxmakingtaxdigital@hmrc.gov.uk and tell us which event location you would be interested in attending. By emailing HMRC, you consent to being contacted before, during, and after the event.

Get ready for MTD step by step

You can find out more information about MTD for Income Tax and what you need to do to get ready for this change by following the MTD agent step by step guide and our agent toolkit.

Resources and timelines

As mentioned in previous Agent Updates, we have communications resources you can share with your clients, alongside a high-level timeline for our external communications.

You will soon start to see more activity around MTD for Income Tax across channels, including social, online and sector specific radio stations. We would be grateful if you could re-post content from HMRC channels to help educate your audiences about the changes.

HMRC Agent Services

Tax advice — do not let your clients fall into the trap of tax avoidance

HMRC’s ‘Don’t get caught out’ campaign helps people working as contractors by empowering them to spot the warning signs of tax avoidance and provides support to get out and get back on track if involved in tax avoidance.

To help your clients avoid the financial pitfalls of tax avoidance, we would encourage you to share our:

  • online guides that explain how to spot tax avoidance and a short You Tube video explaining how umbrella companies operate

  • interactive tools that help workers check if their contracts involve tax avoidance or review their payslips, so they can be confident they are paying the correct amount of tax

  • real-life stories shared by people who want to help others steer clear of tax avoidance

By sharing this information, you can equip your clients with the knowledge they need to make informed and compliant decisions. 

Contractors can also review our published list of named tax avoidance schemes and their promoters. Importantly, it is not an exhaustive list and HMRC never approves such schemes, no matter what some promoters claim.

We would be grateful if you could spread the word by using our ready to go campaign resources in your newsletters, on your websites and across your social media channels. Including sharing and liking our posts on Facebook, LinkedIn, and X. Every share helps protect more people from bad tax advice.

Agent Maintainer correspondence address

HMRC’s Agent Maintainer Team (which forms part of our Agent Compliance Team) has a new postal address.

If you need to correspond with the team, write to the following address:

Agent Compliance Team 
HM Revenue & Customs 
BX9 2BG

Register clients for Self Assessment now

Tax agents should ensure any clients who are new to Self Assessment (SA) and who need to submit a tax return for the 2024 to 2025 tax year have registered for SA. Clients must notify chargeability before 5 October 2025 to avoid a penalty.  

Why it matters 

Clients with income that has not been taxed have a legal obligation to notify HMRC — this is usually done through SA tax returns.

Registering now ensures they will receive their Unique Taxpayer Reference (UTR) and notice to file in good time. 

Tax returns from customers who have not registered or reactivated their SA account take longer to process. This can lead to unnecessary delays; incorrect tax calculations and repayments being issued incorrectly. 

What agents should do 

You should:

‘Tax Help for hustles’ campaign — new resources for agents and their clients

HMRC’s ‘Tax help for hustles’ campaign helps those with side hustles get their tax right.  

Since February 2025, the campaign has supported those that earn additional income (outside of their day job) to get their tax right. Whether it’s digital content creation, selling clothes online, or tutoring, side hustles are becoming an increasingly important part of Britain’s economy, contributing to job creation and economic growth.

The campaign plays an important role in promoting tax compliance, supporting people that, according to research, are largely unaware of their tax responsibilities.

We are asking Agents to share and promote our campaign with clients who may find it useful. You can use our new campaign resource pack.

Protect your agent account from phishing scams

Criminals are using increasingly sophisticated methods to target tax agents, including phishing emails claiming to be from realistic companies, clients and HMRC. This is an attempt to steal personal information from you and your clients. If your device becomes infected, a criminal may have access to everything you use it for, including your agent online services account or agent services account.

Emails claiming to be from HMRC can look genuine with the GOV.UK logo, colour scheme and font. They may also use similar language and use a real policy or plausible process.

How to tell if an email from HMRC is genuine 

We will only ever email you from an email address that ends in gov.uk as can be seen in the following examples:

  • @hmrc.gov.uk

  • @tax.service.gov.uk

  • @advice.hmrc.gov.uk

  • @updates.hmrc.gov.uk

 The gov.uk will only feature at the end of an email address, not in the middle.

You can also check if an email received from HMRC is genuine to help you decide if the email you have received is a scam.

What to do if you receive a phishing email that mentions HMRC 

If you receive a phishing email that mentions HMRC you can report it by forwarding it to phishing@hmrc.gov.uk

You can also report suspicious HMRC texts, social media accounts and phone calls.

By reporting suspicious activity, you can help stop other people falling victim to scams.

What to do if you think you have been a victim of fraud

If you have noticed any suspicious account activity, for example to your Agent Services Account or Agent Account Managers service, do not attempt to correct anything yourself.

Report it immediately to the online services team.

You will need to provide us with contact details in case we need to get back in touch for more information to help us investigate your case. We will let you know the outcome of our investigations.

Read more information 

You can read:

2024 to 2025 Self Assessment Special cases Individuals and Special Exclusions Trust updates

The Self Assessment (SA) Specials Document for Individuals and Special Exclusions for Trusts which sets out whether SA customers should file a paper tax return rather than an online one, has been updated. 

Read more information on :

Self Assessment technical specifications 2025 for individuals

Self Assessment technical specifications 2025 for trust and estate returns

Update on Winter Fuel Payments recovery through the tax system

From Winter 2025, the eligibility criteria for Winter Fuel Payments in England, Wales and Northern Ireland, and the Pension Age Winter Heating Payment in Scotland, will be expanded so that more pensioners are eligible.

If an individual has a total income of over £35,000, HM Revenue and Customs (HMRC) will recover winter payments through the tax system. A charge to income tax will apply that is equal to the full value of the payment received. The tax charge will apply in all parts of the UK.

For your clients who are PAYE customers, HMRC will automatically collect the payment through a change to the customer’s tax code, unless they already file a Self Assessment tax return. Changing the tax code will mean their Winter Fuel Payment will be deducted from their income and paid to HMRC in monthly instalments across the 2026 to 2027 tax year, starting from April 2026.

Your clients who are Self Assessment customers, do not need to include their payment in this year’s tax return. If they complete an online tax return each year HMRC will automatically include the payment on their 2025 to 2026 tax return, due by 31 January 2027. If they file a paper Self Assessment tax return, they will need to include the payment on their 2025 to 2026 tax return, due by 31 October 2026. No one is required to register for Self Assessment because of the winter payments.

The following guidance pages on GOV.UK have been updated to provide further detail on HMRC’s recovery approach:

HMRC has also provided a calculator to help customers check if their income will be over £35,000.

Agent Engagement

Feedback from Professional bodies meeting

Professional Bodies met on 6 August to discuss the way forward now that the Agent Online forum has closed. It was agreed that the Issues Overview Group in its current form has run its course, but there is firm commitment to establish new ways to manage and escalate issues, looking firstly at relevant existing forums, but also to ensure all key work areas have a clear route. HMRC will continue to work with Professional Bodies and agents in practice to develop the approach.  

Self Assessment Voluntary Returns 

To avoid repayment delays, Agents are reminded to re-register their clients for Self Assessment and wait for the notice to file, before they submit the Self Assessment Return. 

Agents should also ensure the agent address on the Form 64-8 corresponds with the agent address on the return. The 64-8 should be submitted and processed by HMRC prior to the return being sent. 

Self Assessment Repayments Failing Automation

In Issue 125 of Agent Update we reminded Agents of the common reasons why repayments are inhibited, these are included in our Self Assessment Manual 113010 — Repayments: repayment work lists: w030 inhibited automatic repayments work list. Agents are further reminded of this guidance.

Opportunity for agents to join our forums

HMRC are inviting practising agents to take part in our external stakeholder forums. These forums provide a collaborative space where HMRC and representatives can share insight, build understanding and shape improvements that benefit HMRC and the agent community.

We are currently seeking representations for the following 2 forums:

  • Guidance Strategy Forum an opportunity for agents to support, inform and influence HMRC’s guidance strategy

  • Tax Adviser Expert Panel — a chance to contribute to early policy thinking related to how HMRC works with tax advisers

How the forums work

The forums work in the following way:

  • forums are held quarterly

  • we will randomly select agents from the list of applicants to participate in each forum

  • membership will be managed on a 12-month rotational basis to ensure fair and balanced representation

Reasons to get involved

We are looking for agents who are:

  • actively engaged in practice

  • respectful of confidentiality procedures

  • keen to contribute constructively to service improvement

By volunteering to take part, you will:

  • contribute your professional expertise to help shape HMRC’s approach

  • influence guidance and policy that directly impacts the agent community

  • strengthen collaboration between HMRC and agents

If you are interested in joining the forums, complete the short survey to register by 9 October 2025.

Contact Information for professional and representative bodies

Back to top