Off-payroll working in the private sector reforms

10 months to go until April 2020

Stage 1: identify key stakeholders and all off-payroll workers.

HMRC’s consultation on off-payroll working closed on 28 May 2019 and will inform the draft legislation on this area which is due to be published in the coming months.

While we wait for the draft legislation, an important first and proactive step is to identify key stakeholders and all off-payroll workers. This includes all current engagements with intermediaries including personal service companies and agencies that may supply labour to your organisation.

Completing these tasks early on will enable you to:

Step 1


Step 2


Step 3


Evaluate how exposed is your organisation.

Do you mostly engage off-payroll workers in a particular business functions e.g. IT? Can this function be fully outsourced instead?

Are these workers engaged regularly?



Communicate potential impacts to key stakeholders ensuring they are part of future discussions on this topic.

Who are the affected populations?

To feel comfortable with the position, do you need to conduct an employment status review on any individuals or seek specialist advice?



Give yourself time to make and implement any changes needed ahead of 6 April 2020.

Including stage two which will be made available in the next issue of Employers Digest, our regular employment taxes newsletter.

Note: that any changes to off-payroll worker status may have an employment law impact as well as a tax and NIC implication, and so you should take all considerations into account.

Off-payroll working in the private sector reforms

The story so far and the processes to be put in place before April 2020.

Contact us

Caroline Harwood
Caroline Harwood
Partner, Head of Share Schemes and Employment Tax