Employment Intermediaries Reports: What UK Recruitment Agencies Need to Send HMRC

Four times a year, a lot of recruitment agencies owe HMRC a spreadsheet they’ve never heard of. It isn’t payroll, it isn’t VAT, and it doesn’t show up in your accounts software. It’s the employment intermediaries report, and if you place limited company or umbrella contractors, it’s very likely yours to send.

I’ve spent seven years in recruitment software, and this is one of those jobs that tends to be owned by nobody. Payroll assumes finance does it, finance assumes the bureau does it, and the first anyone hears of it is a £250 penalty letter. So here’s what the report is, who sends it, what goes in it and how to stop it becoming a quarterly scramble.

As with my other posts, this is a plain-English summary of HMRC’s guidance as it stands in November 2026, not tax advice. Every rule links to its GOV.UK source.

The short version

• If you supply workers to clients and don’t run PAYE on what they’re paid, you probably have to report them to HMRC at least once a quarter (GOV.UK, employment intermediaries: what this means for an intermediary).
• The deadlines are 5 August, 5 November, 5 February and 5 May, one calendar month after each tax quarter ends.
• Late reports get an automatic penalty: £250, then £500, then £1,000 for repeat offences within 12 months.
• No workers in the quarter still means a report. You send a nil report.

Who has to send it

HMRC says you must send a report if all of these apply at any point in the quarter. You:

• are an agency or intermediary that supplies the services of individuals to a client
• have a contract with the client
• supply more than one worker’s services because of that contract
• supply services in the UK, or overseas by someone who is UK resident
• make one or more payments for those services, including payments to third parties

That describes nearly every contract desk. What takes you out of it is running PAYE. HMRC’s manual is clear that the report is about workers left out of your RTI submissions, so an agency that operates PAYE on all its workers doesn’t have to send one (HMRC Employment Status Manual, ESM2105).

You’re also out of it if you supply workers to another agency that holds the client contract (they report, using details you give them), or if you only take an introduction fee and aren’t involved in what follows.

Who goes on it

This is the bit people get wrong. It’s not just limited company contractors.

• Your own PAYE workers: leave them off. They’re already in your RTI submissions.
• Limited company contractors: include them, with what you paid their company in the quarter, the company’s name and address, and its Companies House number.
• Umbrella workers: include them too. The umbrella runs PAYE, so you don’t need to report the payment, but the worker’s details still go on the report (GOV.UK, how to use the employment intermediaries template).
• Sole traders and partnerships: include them, with their unique taxpayer reference (UTR).

For every worker you include, you give a reason why you didn’t operate PAYE, from a list of codes. A limited company contractor is ‘D’, and an umbrella worker is ‘F’, which means another party operated PAYE.

What about Ltd contractors inside IR35? If you’re the deemed employer, you deduct tax and NI and report those payments through your own RTI, as I covered in IR35 for recruitment agencies. On my reading of ESM2105, those payments are already in your payroll submission, so they don’t belong on this report. If your setup is anything other than straightforward, check it with your accountant.

What goes in each row

For each worker, the template needs:

• their name, address and postcode
• their National Insurance number, or their date of birth and gender if they don’t have one
• the start date of the engagement, and the end date if it ended during the quarter
• the reason code for not operating PAYE
• for Ltd and self-employed workers, the amount you paid for their services in the quarter, including expenses and VAT, whether VAT was charged, and who you paid

None of that is difficult on its own. The trouble is where it lives: NI numbers in onboarding paperwork, Companies House numbers in supplier records, dates in the placement and payments in the accounts software. Pulling it together from four places once a quarter is exactly how mistakes creep in.

How to send it

You have to use HMRC’s template, either the CSV or ODS version, and upload it through the employment intermediaries online service (GOV.UK, send an employment intermediary report). To enrol, you need a Government Gateway organisation account, your employer PAYE reference and your Accounts Office reference.

Use a fresh copy of the template each time and don’t change its layout. You can check a file for formatting errors before sending it, and you don’t have to wait for quarter end: weekly or monthly uploads are fine.

Deadlines and penalties

Reporting period	Deadline
6 April to 5 July	5 August
6 July to 5 October	5 November
6 October to 5 January	5 February
6 January to 5 April	5 May

Late reports get an automatic penalty of £250 for the first offence, £500 for the second and £1,000 for the third and any after that, counted over 12 months. If you keep failing to send them, HMRC can charge up to £600 a day.

Being on time isn’t enough, though. An incomplete report counts as incorrect, and penalties for those are decided case by case. Replacing a wrong report before the next deadline, without being asked, is taken into account.

Keep the evidence

You have to keep records for at least three years showing that what you reported was right, and why you didn’t operate PAYE on each worker’s payments. For umbrella workers, that overlaps with the due diligence you should already be doing. Since April 2026, if an umbrella in your chain doesn’t pay the PAYE it owes, HMRC can come to you for it. I covered that change in PAYE vs umbrella vs limited company contractors.

Make it a by-product, not a project

The agencies that find this report painless don’t do anything clever. They just keep the data it needs on the placement from day one, rather than hunting it down at quarter end:

• the worker’s NI number, captured at onboarding
• for Ltd contractors, the company name, address and Companies House number, alongside the VAT details you already need for self-billing
• the umbrella each worker is paid through
• start and end dates that are actually updated when a placement ends or extends
• payments recorded against the placement, not just in the bank

If those are right, the report is a filter and an export. If they aren’t, it’s hours of copying and pasting every quarter, with a penalty if you get it wrong. As I said in the cost of getting pay and bill wrong, errors in the source data don’t stay put.

Where Paid & Billed fits in

I’m building Paid & Billed for small UK contract desks as a focused pay and bill tool that works alongside your existing payroll provider, and every field in this report is already something a placement has to hold to pay and bill people properly. The plan is to keep it there, so the quarterly report comes out of the data you already pay contractors and invoice clients from, rather than a spreadsheet you build at the last minute.

It’s still in development, so I’m not going to pretend it does that today. But if you send this report every quarter and have opinions on what makes it painful, I’d love to hear them. Join the waitlist to follow along and help shape what gets built.