When does this client have to join Making Tax Digital for Income Tax? Four questions

This questionnaire is for a practice working through its Self Assessment clients one at a time. It asks what kind of income the client has, the qualifying income on the 2024 to 2025 return, the figure for 2025 to 2026, and whether one of HMRC's exemptions applies. It gives one of eight outcomes: the date the client starts, the exemption that keeps them out, or the reason they are not in yet, with the steps that follow. The rules are the ones on three GOV.UK pages as we read them on 2 October 2026. Qualifying income means gross income from self-employment and property, before expenses.

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MTD for Income Tax: when this client starts

Answer each question. Some questions appear only when an earlier answer makes them relevant. Nothing you choose leaves this page.

1. What self-employment or property income does the client have in their own name?ChooseSelf-employment or property income, still runningThey had it, but every source stopped before 6 April 2026Only a share of a partnership's profitNone: employment, dividends or pensions only
2. What was the client's qualifying income on the 2024 to 2025 tax return?ChooseOver £50,000£50,000 or less, or no such income on that return
3. What is the client's qualifying income for the 2025 to 2026 tax year?ChooseOver £30,000Over £20,000, up to £30,000£20,000 or less
4. Does one of HMRC's exemptions apply to the client?ChooseNo, none of theseYes, one of the lasting exemptionsYes, one that lasts only until April 2027They cannot use software: age, disability, belief or no internet

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The outcome is the rule as our guides and the sources named set it out, applied to the answers you gave. It is not advice on your own case.

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The questions, and why each is asked

1. What self-employment or property income does the client have in their own name? MTD for Income Tax applies to sole traders and landlords registered for Self Assessment. GOV.UK says a partner's share of partnership profit, employment income, dividends and pensions do not count towards qualifying income.

2. What was the client's qualifying income on the 2024 to 2025 tax return? Qualifying income is gross income from self-employment and property added together, before expenses. HMRC took it from the 2024 to 2025 return to decide who had to start on 6 April 2026. This question appears only when an earlier answer makes it relevant.

3. What is the client's qualifying income for the 2025 to 2026 tax year? The second step uses the 2025 to 2026 return, due by 31 January 2027: over £30,000 means a start on 6 April 2027. Add up the gross figures now if the return has not been prepared. This question appears only when an earlier answer makes it relevant.

4. Does one of HMRC's exemptions apply to the client? GOV.UK's lasting exemptions: no National Insurance number, an attorney or deputy acting for incapacity, ministers of religion, Lloyd's members, Married Couple's or Blind Person's Allowance. Averaging relief, qualifying care relief, SA107 and SA109 last until April 2027. This question appears only when an earlier answer makes it relevant.

Every outcome, and the rule behind it

Outside Making Tax Digital for Income Tax for now

Reached when: "What self-employment or property income does the client have in their own name?" answered "Only a share of a partnership's profit" or "None: employment, dividends or pensions only".

GOV.UK, read on 2 October 2026, says MTD for Income Tax applies to sole traders and landlords whose qualifying income is over the threshold. A partner's share of partnership profit, employment income, dividends and pensions do not count towards qualifying income. Partnerships will be brought in later, and HMRC has not yet set the timeline. The client carries on sending a Self Assessment return as normal.

• Note on the client file that the income test was done, with the date and the figures used.
• Run the test again if the client starts a trade or lets a property in their own name.

Source: GOV.UK, Find out if and when you need to use Making Tax Digital for Income Tax (updated 26 March 2026) and Work out your qualifying income (updated 11 September 2026), read 2 October 2026. The working is in MTD for Income Tax deadline checker.

Not in, but HMRC has to be told that every source has stopped

Reached when: "What self-employment or property income does the client have in their own name?" answered "They had it, but every source stopped before 6 April 2026".

GOV.UK says a client whose self-employment and property income all ceased before 6 April 2026 does not need to use MTD for Income Tax. If HMRC is not told, it will sign the client up on the information it holds. Where the 2025 to 2026 return showing the cessation has not been submitted, contact HMRC, which updates its record and sends a letter confirming the client is out. The return is still due by 31 January 2027. If one source stopped and another continues, the stopped source still counts: answer the first question as still running.

• Contact HMRC if the 2025 to 2026 return showing the cessation has not gone in yet.
• File the 2025 to 2026 return on time, showing the income up to the date each source stopped.
• Keep HMRC's confirmation letter on the client file.

Source: GOV.UK, Work out your qualifying income for Making Tax Digital for Income Tax, section on ceased income sources (updated 11 September 2026), read 2 October 2026. The working is in How to sign up a client for MTD for Income Tax as an agent.

Not in before 6 April 2028 at the earliest

Reached when: "What is the client's qualifying income for the 2025 to 2026 tax year?" answered "Over £20,000, up to £30,000" or "£20,000 or less".

The client was at or under £50,000 for 2024 to 2025 and is at or under £30,000 for 2025 to 2026, so neither of the first two start dates applies. The last step uses the 2026 to 2027 return: qualifying income over £20,000 means a start on 6 April 2028. GOV.UK says anyone at £20,000 or less is automatically exempt. The test is gross income before expenses, so a client between £20,000 and £30,000 now should expect to come in on that date.

• Diary a fresh test when the 2026 to 2027 figures are known, after 5 April 2027.
• Tell a client who is over £20,000 now that April 2028 is likely, and start digital records early.
• Check the figure is gross income from every source added together, not profit.

Source: GOV.UK, Find out if and when you need to use Making Tax Digital for Income Tax (updated 26 March 2026) and Find out if you can get an exemption (updated 28 May 2026), read 2 October 2026. The working is in MTD for Income Tax deadline checker.

A lasting exemption applies: check whether it is automatic

Reached when: "Does one of HMRC's exemptions apply to the client?" answered "Yes, one of the lasting exemptions".

GOV.UK lists exemptions that do not end in April 2027: no National Insurance number before the tax year starts, a power of attorney or court-appointed deputy acting because of incapacity, ministers of religion (page SA102M), Lloyd's members (page SA103L), and Married Couple's or Blind Person's Allowance. Where the 2024 to 2025 return already showed the page or claim, the exemption is automatic and nothing is sent to HMRC. Where the minister's page or one of the two allowances first appears on a later return, the client has to apply. An exempt client still files a Self Assessment return.

• Check the 2024 to 2025 return for the page or claim; if it is there, do not sign the client up.
• If the minister's page or an allowance first appears on a later return, apply through GOV.UK.
• Record the exemption and the evidence for it on the client file.

Source: GOV.UK, Find out if you can get an exemption from Making Tax Digital for Income Tax (updated 28 May 2026), read 2 October 2026. The working is in MTD for Income Tax checklist for accountants.

Apply for the digitally excluded exemption before signing up

Reached when: "Does one of HMRC's exemptions apply to the client?" answered "They cannot use software: age, disability, belief or no internet".

A client is digitally excluded where it is not reasonable for them to use software to keep digital records or send updates, because of age, a health condition or disability, religious belief, or no internet access at home, at work or at a suitable alternative place. This exemption is never automatic: it is applied for, and HMRC decides each case. GOV.UK says HMRC will not accept an application whose only reason is a previous paper return, unfamiliarity with software, few records or the extra time or cost. A client HMRC already treats as digitally excluded for VAT contacts HMRC instead.

• Write down the client's reason and test it against the four reasons HMRC will not accept.
• Apply through GOV.UK; an agent can apply, but the test is the client's own circumstances.
• Do not sign the client up while the application is with HMRC.

Source: GOV.UK, Find out if you can get an exemption from Making Tax Digital for Income Tax, section on the digitally excluded exemption (updated 28 May 2026), read 2 October 2026. The working is in MTD for Income Tax checklist for accountants.

Exempt for 2026 to 2027 only: the start moves to 6 April 2027

Reached when: "Does one of HMRC's exemptions apply to the client?" answered "Yes, one that lasts only until April 2027"; "What was the client's qualifying income on the 2024 to 2025 tax return?" answered "Over £50,000".

A 2024 to 2025 return with a claim for averaging relief on the SA103 page, a claim for qualifying care relief, or the SA107 or SA109 page gives an automatic exemption for the 2026 to 2027 tax year, with nothing to send to HMRC. If one of these will first appear on a later return, the client applies instead. The exemption runs out in April 2027: GOV.UK says the client must use MTD for Income Tax from the 2027 to 2028 tax year if qualifying income for 2025 to 2026 is over £30,000.

• Confirm the claim or page is on the 2024 to 2025 return as filed, and keep a copy.
• Test the 2025 to 2026 income against £30,000 now, so that April 2027 is not a surprise.
• Use 2026 to 2027 to set up software and the authorisation without quarterly deadlines.

Source: GOV.UK, Find out if you can get an exemption from Making Tax Digital for Income Tax, sections on exemptions that last until April 2027 (updated 28 May 2026), read 2 October 2026. The working is in MTD for Income Tax deadline checker.

In since 6 April 2026: sign up now if it has not been done

Reached when: "What was the client's qualifying income on the 2024 to 2025 tax return?" answered "Over £50,000".

Qualifying income over £50,000 on the 2024 to 2025 return means the client should have been using MTD for Income Tax from 6 April 2026. Quarterly updates for 2026 to 2027 are due on 7 August, 7 November, 7 February and 7 May. GOV.UK says there is no penalty for a late quarterly update in 2026 to 2027, but the tax return cannot be submitted without them. From September 2026 HMRC signs up anyone who should be in and is not, using only the information it already holds.

• Check whether the client is signed up, by the practice, by the client or by HMRC.
• Add the Self Assessment authorisation to the agent services account, then sign the client up.
• Send any missed quarterly update from compatible software as soon as the records are in.
• File the 2025 to 2026 return by 31 January 2027 in the usual way.

Source: GOV.UK, Find out if and when you need to use Making Tax Digital for Income Tax (26 March 2026), Sign up your client (24 August 2026) and Penalties for Making Tax Digital for Income Tax (30 March 2026), read 2 October 2026. The working is in How to sign up a client for MTD for Income Tax as an agent.

In from 6 April 2027

Reached when: any other set of answers.

Qualifying income over £30,000 for the 2025 to 2026 tax year brings the client into MTD for Income Tax from 6 April 2027. HMRC takes the figure from the 2025 to 2026 return, due by 31 January 2027, and writes to those over the threshold; GOV.UK says the duty to check and sign up stands even if no letter comes. An exemption that lasts only until April 2027 does not change this date. From the 2027 to 2028 tax year a missed quarterly deadline earns a penalty point; the deadlines are 7 August, 7 November, 7 February and 7 May.

• Tell the client in writing now, with the date and what changes for them.
• Choose the software and get the authorisation in place before April 2027.
• Sign the client up; GOV.UK allows sign-up for the current tax year or the next one.
• Put a date for sending records before each quarterly deadline in the engagement letter.

Source: GOV.UK, Find out if and when you need to use Making Tax Digital for Income Tax (26 March 2026), Sign up your client (24 August 2026) and Penalties for Making Tax Digital for Income Tax (30 March 2026), read 2 October 2026. The working is in MTD for Income Tax checklist for accountants.

How to use the result

Write the outcome and the date on the client file, with the income figures you used. A start date is a planning date: the client needs software, an authorisation in the agent services account and a date for sending records before the first quarter ends. Run the questions again when the next return is prepared, because each tax year's figure is tested against a lower threshold than the last. Where the outcome is an exemption, keep the evidence for it with the file. Tax advice and sign-off stay with the accountant.

The outcome applies the rule to the answers given; it cannot see the facts behind them. Where an answer is a judgement, or the facts are unusual, the outcome may not fit. This page is general information, not legal advice.

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