Register and maintain subcontractor: the registration process: NINO
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Newly Self Employed customers registering for Self Assessment and CIS
All newly self-employed customers registering for Self Assessment (SA) only, or SA and CIS, must establish their identity before their registration for SA can be processed. The proper way to do this is for the person to provide a verifiable NINO. By verifiable NINO, we mean one that can be traced on HMRC computer systems. Even if the applicant offers sight of a National Insurance card, you must still check the NINO on HMRC computer systems (however see below where the customer has only recently attended an Evidence of Identity interview with DWP).
A CIS application form CIS301 (Individual), CIS302 (Individual) and CIS304 (Partner) is therefore not complete without a NINO. This should be entered by the applicant in the relevant section of the form.
The NINO on the application form will need to be verified as part of the authentication process. This is to ensure that the identity of the applicant has been established before the application is processed. If the NINO is verified as belonging to the applicant on HMRC systems the operator can proceed with registration. The applicant may be able to obtain their NINO from any of the following:
- National Insurance card - RD3
- Form RD1138/CA1019 - quarterly bill for Class 2 National Insurance Contributions
- Form CA2347 - Bank mandate for Class 2 NIC deductions
- Form RD170 - deficiency notice
- Any other official document or letter on headed note-paper issued from the Benefits Agency or HMRC National Insurance Contributions Office (NICO).
Where the applicant is not already registered for Self-Assessment and does not hold a United Kingdom National Insurance Number (NINO), then the applicant should be advised to apply for one by telephoning the Department for Work and Pensions (DWP) on 0845 600 0643. As part of this process, they will be asked by DWP to attend an Evidence of Identity interview. Once the customer has their United Kingdom NINO, the SA/CIS registration process can proceed as normal. Where the customer claims not to be liable to UK National Insurance see the guidance below.
Customers who already have a Self-Assessment record open but do not have a verifiable UK NINO
Where the applicant is already registered for Self-Assessment but does not hold a UK NINO, then the applicant should be advised to apply for one by telephoning the Department for Work and Pensions (DWP) on 0845 600 0643. As part of this process, they will be asked by DWP to attend an Evidence of Identity interview. Once the customer has their UK NINO, the SA/CIS registration process can proceed as normal. Where the customer claims not to be liable to UK National Insurance see the guidance below.
Customers who have recently attended an Evidence of Identity interview with DWP
If the customer has recently attended a DWP Evidence of Identity interview and now wants to register for SA and CIS and produces a letter from DWP with their NINO on it, you must accept this without question. The completed forms with the NINO will be sent to the NICO CIS team who will check NIRS2 to see if the NINO is now registered on HMRC systems, if it is not they are able to verify the NINO on DWP systems using ADD, and then proceed with registration for SA and CIS as normal.
Alternative process for customers claiming not to be liable for UK National Insurance
However, you should be aware that not every customer will need a UK NINO because, in a very few cases, they do not have to pay UK National Insurance. Therefore, if anyone seeking registration for SA and CIS, tells you that they are not liable for National Insurance in the UK, you should make an appointment for them at a UK venue for them to prove their identity.
Customers from the Isle of Man
Residents of the Isle of Man should have been issued with a NINO commencing with the letters ‘MA’. These NINOs are valid in the UK and the guidance at NIM39620 refers.