HMRC Reporting Requirements for Employment Intermediaries (Recruitment Agencies)

4 November 2014

HMRC has issued guidance on the quarterly reporting requirements that will be required to be sent to HMRC for employment intermediaries, such as recruitment agencies, from 6th July 2015. The first report must be sent to HMRC by 5th August 2015 and will cover the 3 months from 6th April 2015 to 5th July 2015.

The guidance also states that from 6th April 2014 you must be able to demonstrate, if asked, why a worker has not been treated as an employee and paid through PAYE.

The guidance requires that the recruitment agency reports details of workers that it hasn’t treated as employees because they are paid PAYE elsewhere (i.e. through an umbrella company or their own limited company) or because they are not under the agency’s control or supervision. These workers are people who the agency has helped supply contractually to an end client in the UK and that are paid for in respect of this ongoing service (i.e. covers contractors supplied to fulfill temporary contracts but not recruitment of permanent staff).

Excluded workers are the following categories: actor, singer, musician, other entertainer, or a fashion, photographer’s or artist’s model.

If you are sending a report you must include:

  • your full name, address, postcode and PAYE reference
  • the start and end dates of the reporting period
  • the worker’s personal details
  • the engagement and payment details

For each worker you need to disclose:

  • title
  • full name
  • date of birth
  • gender
  • address and postcode
  • National Insurance number (if they have one)
  • passport number (if they don’t have a National Insurance number)
  • national identity card number (if they don’t have a National Insurance number or a passport number)
  • unique taxpayer reference (if they are self-employed or a member of a partnership)

This is information that Umbrella could help potentially helped recruitment agencies collate.

The Guidance has come under criticism from APSCo who have been reported as saying that they are appalled by the requirements which they consider to be onerous and by the fact that HMRC have ignored concerns that have been raised.

A copy of the full guidance is available on the Government website:

At Umbrella we are looking at how we can aid recruitment agencies in fulfilling their reporting requirements and will be issuing our guidance shortly.

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