Construction Industry Scheme responsibilities

The Construction Industry Scheme (CIS) is used within the UK construction sector to help manage payments between contractors and subcontractors effectively. This scheme mandates that contractors deduct a portion of payments made to subcontractors, remitting these funds directly to HMRC. These deductions function as advance payments towards the subcontractor’s tax and National Insurance obligations.

A significant administrative update to the CIS scheme took effect from 6 April 2026. From this date, construction contractors are once again required to file a nil return for any month in which they have not paid subcontractors. This reinstatement of the nil filing obligation aims to prevent erroneous late filing penalties that previously arose when contractors did not make payments but also did not inform HMRC. Contractors are required to either file a nil return or notify HMRC in advance if they will not be making any subcontractor payments for a given month; failure to do so without a reasonable excuse could result in penalties.

For any business operating within the construction sector, whether based in the UK or abroad, a thorough understanding of the CIS regulations is important. Beyond mere compliance, accurate registration, precise deductions, and punctual submissions are fundamental to sound financial governance and crucial for avoiding potential penalties. 

Contractors are required to register for the scheme. While subcontractors are not required to register, a higher rate of deduction will be applied to their payments if they are unregistered. Registered contractors can use CIS online to file monthly returns or verify subcontractors.

Businesses must register as a contractor if they pay subcontractors for construction work, or if their business, despite not performing construction work itself, has spent over £3 million on construction in the 12 months since its first payment. Registration as a subcontractor is required if a business undertakes construction work for a contractor. If a business meets the criteria for both, it must register as both a contractor and a subcontractor.

Source:HM Revenue & Customs| 28-06-2026

Construction Industry Scheme: tackling fraud

Tackling fraud in the Construction Industry Scheme (CIS) was one of the measures addressed in the recent Budget. The changes are intended to allow faster intervention where fraud is suspected, while also simplifying certain administrative aspects of the CIS.

From 6 April 2026, HMRC will be able to act immediately where a business makes or receives a payment that it knew, or ought to have known, was connected to fraud. In these cases, HMRC will have the authority to withdraw Gross Payment Status (GPS) straight away, assess the business for any related tax loss and impose penalties of up to 30%. Penalties may apply to the business itself or, in some circumstances, to its officers. Where GPS status is removed due to fraud or serious non-compliance, the business will also be prevented from reapplying for five years, a significant increase from the current one-year restriction.

The government also announced plans to simplify the operation of the CIS. Planned changes include exempting payments made to local authorities and certain public bodies from the scheme and reinstating the requirement for contractors to submit nil returns. These measures are expected to take effect from 6 April 2026, following a period of technical consultation.

The CIS applies special tax and National Insurance rules to construction businesses, with contractors generally required to deduct tax from payments made to subcontractors. Deduction rates depend on whether the subcontractor is registered and whether they hold GPS, which allows payment without deductions.

Source:HM Treasury| 26-01-2026

Construction Industry Scheme changes

As part of the Budget measures, the government confirmed plans to make some changes to the Construction Industry Scheme (CIS).

From 6 April 2026, HMRC will be able to take immediate action where a business makes or receives a payment that it knew, or should have known, was connected to fraud. In these circumstances, HMRC will have the power to remove Gross Payment Status (GPS) with immediate effect, assess the business for the associated tax loss, and impose a penalty of up to 30%. This penalty may be applied to the business itself or to its officers. Where GPS is withdrawn due to fraud or serious non-compliance, the business will also be barred from reapplying for GPS for a period of five years (an increase from the current one-year limit).

Alongside these measures, the government also plans to simplify the CIS by exempting payments to local authorities and certain public bodies. As part of this change the requirement for construction contractors to submit nil returns will be required. These changes are due to take effect from 6 April 2026 and will first be subject to technical consultation.

The CIS is a set of special tax and National Insurance rules for businesses operating in the construction industry. Under the scheme, businesses are classed as either contractors or subcontractors, and both must understand their tax obligations.

Qualifying contractors are required to deduct tax from payments made to subcontractors and pass these deductions to HMRC. The amounts deducted count as advance payments towards the subcontractor’s tax and National Insurance liabilities.

Subcontractors are not required to register for the CIS, but where they are not registered, contractors must deduct tax at a higher rate of 30%. Registered subcontractors are subject to a 20% deduction unless they qualify for GPS. Where GPS applies, no deductions are made by the contractor, and the subcontractor is responsible for paying all tax and National Insurance at the end of the tax year.

To qualify for GPS, a subcontractor must meet specific criteria, including a strong compliance history of paying tax and National Insurance on time, and carrying on a business that undertakes construction work or supplies construction labour in the UK.

Source:HM Treasury| 15-12-2025

CIS – qualifying for gross payment status

The Construction Industry Scheme (CIS) is a set of special rules for tax and National Insurance for those working in the construction industry. Businesses in the construction industry are known as 'contractors' and 'subcontractors' and should be aware of the tax implications of the scheme.

Under the scheme, contractors are required to deduct money from a subcontractor’s payments and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance. Contractors are defined as those who pay subcontractors for construction work or who spent more than £3m on construction a year in the 12 months since they made their first payment.

Subcontractors do not have to register for the CIS, but contractors must deduct 30% from their payments to unregistered subcontractors. The alternative is to register as a CIS subcontractor where a 20% deduction is taken or to qualify for gross payment status whereby the contractor will not make any deductions, and the subcontractor is responsible to pay all their tax and National Insurance at the end of the tax year.

To qualify for gross payment status a subcontractor must meet certain criteria, including having paid their tax and National Insurance on time in the past and have a business that undertakes construction work (or provides labour for it) in the UK.

The subcontractor must also have a turnover of at least £30,000 for a sole trader (or higher depending on the structure of your business). An application for gross payment status can be made online or by post.

Source:HM Revenue & Customs| 12-10-2025

Definition of a building sub-contractor

Know the rules for contractors & subs under CIS to avoid issues with HMRC.

Under the Construction Industry Scheme (CIS), HMRC applies specific tax rules to contractors and subcontractors in the construction industry. Contractors are responsible for deducting tax from payments made to subcontractors and forwarding it to HMRC. These deductions act as advance payments toward the subcontractor’s income tax and National Insurance.

A subcontractor is defined as any business or individual that agrees to perform construction operations for another business (a contractor or deemed contractor). This applies whether the work is done directly or through others such as employees or further subcontractors. Notably, a business typically considered a main contractor can be a subcontractor if hired by another contractor, such as a local authority.

Subcontractors can include:

  • Companies, public bodies, partnerships and self-employed individuals.
  • Labour agencies or staff bureaus that supply or employ workers for construction.
  • Foreign businesses performing construction in the UK or its territorial waters.
  • Local authorities or public bodies engaged in construction work for others.
  • Gang-leaders who agrees with a contractor on the work to be done, and in turn receives payment for the work of the team.

Some businesses function as both contractors and subcontractors, paying others while also being paid for their services. These businesses must follow both sets of CIS rules depending on their role in each transaction.

Source:HM Revenue & Customs| 10-08-2025

CIS monthly returns obligations

The Construction Industry Scheme (CIS) requires contractors to deduct tax from subcontractor payments and file monthly returns with HMRC. Even if no payments are made, nil returns must be submitted to avoid penalties.

The CIS is a specialised set of rules governing tax and national insurance for individuals working within the construction industry. This scheme specifically applies to businesses operating as 'contractors' and 'subcontractors' within the construction sector. Under the provisions of the scheme, contractors are required to deduct money from a subcontractor’s payments and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance.

One of the primary responsibilities for contractors under the CIS is the submission of monthly returns, which must be completed and filed online. These returns correspond to each tax month, which runs from the 6th day of one month to the 5th day of the following month. The deadline for submitting these returns is 14 days after the conclusion of each tax month.

It is important to note that even if no subcontractors have been paid during a particular tax month, contractors are still required to file a 'nil return.' The necessity to submit returns must be met regardless of whether the contractor typically submits PAYE returns on a quarterly basis. Contractors can file their monthly returns using the HMRC CIS online service or through commercial CIS software. Failure to submit the required returns on time may result in penalties and interest charges.

In cases where a contractor has not made any payments to subcontractors during a given tax month, they are still obligated to submit a 'CIS nil return' or inform HMRC that no return is necessary. Should this 'nil return' situation become a long-term occurrence, contractors have the option to request a period of inactivity from HMRC. This request indicates that the contractor has temporarily ceased employing subcontractors and lasts for a period of six months. It is important to notify HMRC if subcontractor payments resume within this time frame, as this could affect the contractor’s obligations under the scheme.

Contractors are defined as those who make payments to subcontractors for construction work or who have spent more than £3 million on construction in the 12 months following their first payment under the scheme.

Source:HM Revenue & Customs| 10-02-2025

Contractors and CIS

The Construction Industry Scheme (CIS) is a set of special rules for tax and National Insurance for those working in the construction industry. Businesses in the construction industry are known as 'contractors' and 'subcontractors' and should be aware of the tax implications of the scheme.

Under the scheme, contractors are required to deduct money from a subcontractor’s payments and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance. Contractors are defined as those who pay subcontractors for construction work or who spent more than £3m on construction a year in the 12 months since they made their first payment. A contractor can be a sole trader, in a partnership or own a limited company.

New contractors must follow these rules:

  1. They must register for CIS before they take on their first subcontractor.
  2. They must check if they should employ the person instead of subcontracting the work. They may get a penalty if they should be an employee.
  3. Check with HM Revenue and Customs (HMRC) that their subcontractors are registered with CIS.
  4. When they pay subcontractors, they will usually need to make deductions from their payments and pay the money to HMRC. Deductions count as advance payments towards the subcontractor’s tax and National Insurance bill.
  5. They need to file monthly returns and keep full CIS records – they may get a penalty if they do not.
  6. They must let HMRC know about any changes to their business.
Source:HM Revenue & Customs| 24-02-2024

CIS contractors monthly tax chores

The Construction Industry Scheme (CIS) is a set of special rules for tax and National Insurance for those working in the construction industry. Businesses in the construction industry are known as 'contractors' and 'subcontractors' and should be aware of the tax implications of the scheme.

Under the scheme, contractors are required to deduct money from a subcontractor’s payments and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance.

Monthly returns must be submitted online. The monthly return relates to each tax month (i.e., running from the 6th of one month to the 5th of the next). The deadline for submission is 14 days after the end of the tax month. Even if no subcontractors have been paid during a month, contractors still have to make a nil return. All contractors are obliged to file monthly returns even if they are entitled to pay their PAYE quarterly. The returns can be filed using the HMRC CIS online service or approved commercial CIS software. There are penalties for late returns.

Contractors who have not paid subcontractors in a particular month are required to submit a 'CIS nil return' or notify HMRC that no return is due. If this is likely to be a longer term ‘nil return’, the contractor can contact HMRC to make an inactivity request stating they have temporarily stopped using subcontractors. This request lasts for 6 months. You must notify HMRC if you start using subcontractors again during this period. 

Contractors are defined as those who pay subcontractors for construction work or who spent more than £3m on construction during a year in the 12 months since they made their first payment.

Source:HM Revenue & Customs| 02-10-2023

The Construction Industry Scheme

The Construction Industry Scheme (CIS) is a set of special tax and National Insurance rules for those working in the construction industry. Businesses in the construction industry are known as 'contractors' and 'subcontractors' and should be aware of the tax implications of the scheme.

Under the scheme, contractors are required to deduct money from a subcontractor’s payments and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance liabilities.

Contractors are defined as those who pay subcontractors for construction work or who spent more than £3m on construction a year in the 12 months since they made their first payment. Subcontractors do not have to register for the CIS, but contractors must deduct 30% from their payments to unregistered subcontractors. The alternative is to register as a CIS subcontractor where a 20% deduction is taken or to apply for gross payment status.

Monthly returns must be submitted online. The monthly return relates to each tax month (i.e., running from the 6th of one month to the 5th of the next). The deadline for submission is 14 days after the end of the tax month. Contractors who have not paid subcontractors in a particular month are required to submit a 'CIS nil return' or notify HMRC that no return is due.

Additionally, new VAT rules for building contractors and sub-contractors came into effect on 1 March 2021. This means that for certain specified supplies, sub-contractors no longer add VAT to their supplies to most building customers, instead, the contractors are obliged to pay the deemed output VAT on behalf of their registered sub-contractor suppliers. This is known as the Domestic Reverse Charge. The contactors can then claim back the output tax paid as input VAT, subject to the usual rules.

Source:HM Revenue & Customs| 24-07-2023

HMRC strike causes CIS delays

Some 400 HMRC helpline service advisers who are members of the Public and Commercial Services (PCS) Union have been on strike intermittingly since 10 May 2023. These strikes are by staff working in HMRC’s East Kilbride and Newcastle offices. The striking workers are with the department of Personal Taxation Operations on Employer Service.

The following are the strike dates that were announced:

  • 10-12 May
  • 15-19 May
  • 22-26 May
  • 29-31 May
  • 1 and 2 June

These dates exclude weekends and effectively mean that employer services were affected until 5 June 2023.

It has been widely acknowledged that these strikes are having a serious impact on HMRC’s helplines which were already struggling to cope with demand. 

Specifically, there have been many reports of long delays to those trying to contact the Construction Industry Scheme (CIS) helpline. The CIS helpline is widely used to help those registering for the CIS and to resolve issues that arise with CIS deduction rates. This means that affected subcontractors may be paying more tax than necessary, with a long wait to recover the overpaid amounts.

The strikes are also having a significant impact on other helplines including the employer helpline, student loans unit, PAYE registrations, maternity, paternity and sick pay.

Source:Other| 31-05-2023

Monthly chores for CIS contractors

The Construction Industry Scheme (CIS) is a set of special rules covering tax and national insurance for those working in the construction industry. Businesses in the construction industry are known as 'contractors' and 'subcontractors' and should be aware of the tax implications of the scheme.

Under the scheme, contractors are required to deduct money from payments to subcontractors and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance.

Monthly returns must be submitted online. The monthly return relates to each tax month (i.e., running from the 6th of one month to the 5th of the next). The deadline for submission is 14 days after the end of the tax month. Even if no subcontractors have been paid during a month, contractors still have to make a nil return. All contractors are obliged to file monthly returns even if they are entitled to pay their PAYE quarterly. The returns can be filed  using the HMRC CIS online service or commercial CIS software. There are penalties for late returns.

Contractors who have not paid subcontractors in a particular month are required to submit a 'CIS nil return' or notify HMRC that no return is due. If this is likely to be a longer term ‘nil return’, then the contractor can contact HMRC to make an inactivity request stating they have temporarily stopped using subcontractors. This request lasts for 6 months. You must notify HMRC if you start using subcontractors again during this period. 

Contractors are defined as those who pay subcontractors for construction work or who spent more than £3m on construction a year in the 12 months since they made their first payment.

Source:HM Revenue & Customs| 08-05-2023

Construction services and reverse charge

New VAT rules for building contractors and sub-contractors came into effect on 1 March 2021. The new rules make the supply of most construction services between construction or building businesses subject to the domestic reverse charge. The reverse charge only applies to supplies of specified construction services to other businesses in the construction sector.

HMRC’s guidance states that you must use the reverse charge for the following services:

  • constructing, altering, repairing, extending, demolishing or dismantling buildings or structures (whether permanent or not), including offshore installation services
  • constructing, altering, repairing, extending, demolishing of any works forming, or planned to form, part of the land, including (in particular) walls, roadworks, power lines, electronic communications equipment, aircraft runways, railways, inland waterways, docks and harbours, pipelines, reservoirs, water mains, wells, sewers, industrial plant and installations for purposes of land drainage, coast protection or defence
  • installing heating, lighting, air-conditioning, ventilation, power supply, drainage, sanitation, water supply or fire protection systems in any building or structure
  • internal cleaning of buildings and structures, so far as carried out in the course of their construction, alteration, repair, extension or restoration
  • painting or decorating the inside or the external surfaces of any building or structure
  • services which form an integral part of, or are part of the preparation or completion of the services described above – including site clearance, earth-moving, excavation, tunnelling and boring, laying of foundations, erection of scaffolding, site restoration, landscaping and the provision of roadways and other access works

This means that for these specified supplies, sub-contractors no longer add VAT to their supplies to most building customers, instead, the contractors are obliged to pay the deemed output VAT on behalf of their registered sub-contractor suppliers. This is known as the Domestic Reverse Charge. On the same VAT return, contractors can claim back the deemed input tax on the supply subject to the usual rules.

Source: HM Revenue & Customs Tue, 17 Aug 2021 00:00:00 +0100

Who counts as CIS contractor or sub-contractor?

The Construction Industry Scheme (CIS) is a set of special rules that affect tax and National Insurance for those working in the construction industry. Businesses in the construction industry are known as 'contractors' and 'subcontractors' and will need to be aware of the tax implications of the scheme.

Under the CIS, contractors are required to deduct money from a subcontractor’s payments and pass it to HMRC. The deductions count as advance payments towards the subcontractor’s tax and National Insurance liabilities.

Contractors are defined as those who pay subcontractors for construction work or who spent more than £3m on construction a year in the 12 months since they made their first payment.

Subcontractors do not have to register for the CIS, but contractors must deduct 30% from their payments to unregistered subcontractors. The alternative is to register as a CIS subcontractor where a 20% deduction is taken or to apply for gross payment status when the contractor will not make any deductions and the subcontractor is responsible to pay all their tax and National Insurance at the end of the tax year.

The CIS covers most construction work carried out in the UK, including jobs such as:

  • site preparation
  • alterations
  • dismantling
  • construction
  • repairs
  • decorating
  • demolition

Exceptions to the definition of construction work includes professional work done by architects and surveyors, carpet fitting, scaffolding hire (with no labour) and work on construction sites that’s clearly not construction. The CIS does not apply to construction work carried on outside the UK.

Source: HM Revenue & Customs Tue, 27 Jul 2021 00:00:00 +0100

CIS – types of work and businesses affected

The Construction Industry Scheme (CIS) is a set of special rules for tax and National Insurance for those working in the construction industry. 

The CIS covers all construction work carried out in the UK, including jobs such as:

  • site preparation
  • alterations
  • dismantling
  • construction
  • repairs
  • decorating
  • demolition

Exceptions to the definition of construction work includes professional work done by architects and surveyors, carpet fitting, scaffolding hire (with no labour) and work on construction sites that’s clearly not construction. The CIS does not apply to construction work carried on outside the UK. 

The scheme covers all types of businesses and other concerns that work in the construction industry, including:

  • companies
  • partnerships
  • self-employed individuals

Businesses in the construction industry are known as 'contractors' and 'subcontractors'.

New VAT rules for building contractors and sub-contractors came into effect from 1 March 2021. The new rules will make the supply of most construction services between VAT registered construction or building businesses subject to the domestic reverse charge. The reverse charge only applies to supplies of specified construction services to other businesses in the construction sector. This means that sub-contractors no longer add VAT to their supplies to most building customers, instead, contractors are obliged to pay the deemed output VAT on behalf of their registered sub-contractor suppliers. 

Source: HM Revenue & Customs Wed, 05 May 2021 00:00:00 +0100

VAT Reverse charge for construction sector

A further reminder that new VAT rules for building contractors and sub-contractors will come into effect from 1 March 2021. The new rules were originally expected to commence from 1 October 2019, but an initial 12 month delay was announced. The start date was then delayed for a further 5 months until 1 March 2021 due to the impact of the coronavirus pandemic.

The new rules will make the supply of most construction services between construction or building businesses subject to the domestic reverse charge. The reverse charge will only apply to supplies of specified construction services to other businesses in the construction sector.

This means that from 1 March 2021, sub-contractors will no longer add VAT to their supplies to most building customers, instead, contractors will be obliged to pay the deemed output VAT on behalf of their registered sub-contractor suppliers. This is known as the Domestic Reverse Charge. However, there is no loss of cashflow as the deemed output VAT can be deducted as input VAT subject to any existing restrictions; in this way the two entries on VAT returns cancel each other out.

This change will mean you that contractors will have to alter the way that supplies from sub-contractors are treated by their accounting software.

HMRC’s guidance states that, for invoices issued for specified supplies that become liable to the reverse charge, the VAT treatment for invoices with a tax point:

  • before 1 March 2021 – the normal VAT rules will apply, and VAT registered subcontractors should charge VAT at the appropriate rate on supplies
  • on or after 1 March 2021 – the domestic reverse charge will apply.
Source: HM Revenue & Customs Wed, 13 Jan 2021 00:00:00 +0100