# Employment intermediary report to HMRC: the 5 November 2026 deadline, who goes on it and the £250 penalty

> The HMRC employment intermediary report for 6 July to 5 October 2026 is due by 5 November 2026. Who goes on it, the details to collect, and the penalties.

- Page to cite: https://aeolookup.com/recruitment/employment-intermediary-report-hmrc-deadline-5-november-2026/
- Publisher: AEO Lookup (https://aeolookup.com/)
- Section: Recruitment agencies, Running the agency
- Published 1 October 2026
- Key fact: The employment intermediary report for 6 July to 5 October 2026 is due at HMRC by 5 November 2026 and lists every worker an agency supplied and paid without operating PAYE; a late report brings an automatic £250 penalty, £500 for a second in 12 months and £1,000 for a third, so three missed quarters cost £1,750.
- Sources: GOV.UK "Employment intermediaries reporting requirements: what this means for an intermediary" (updated 30 July 2026), "How to use the employment intermediaries template", "Check if you're an employment intermediary" (updated 8 May 2026) and "Submit an employment intermediary report"; HMRC Employment Status Manual ESM2115 and ESM2190 (updated 16 September 2025); each read in a browser render on 2026-10-01. The example agency and the email wording are ours. Not tax advice.

The next employment intermediary report is due at HMRC by 5 November 2026. It covers 6 July to 5 October 2026 and lists every worker your agency supplied to a client and paid without operating PAYE. A late report brings an automatic £250 penalty.

The quarter closes on Monday 5 October, so the details are easiest to collect now.

**Free tool on the page:** HMRC intermediary report details request maker. It runs in the browser at https://aeolookup.com/recruitment/employment-intermediary-report-hmrc-deadline-5-november-2026/#tool and asks for no sign-up.

## Does your agency have to send one

HMRC says you must report if all of these apply at any time in the period. You:

- supply the services of individuals to a client
- hold the contract with that client
- provide more than one worker's services
- provide the services in the UK, or overseas where the worker is UK resident
- make one or more payments for the services, including payments to third parties

You do not report if you are a UK employer supplying workers straight to end clients and you run PAYE on all of their pay. A desk that only introduces candidates for permanent jobs, with no part in what follows, does not report either.

The agency holding the client contract sends the report. A second-tier supplier passes its workers' details up the chain. If you are an intermediary and supplied no workers in a quarter, HMRC says you must file a nil report by the same deadline.

## The four quarters

| Reporting period | Report due | Last day to replace it |
|---|---|---|
| 6 April to 5 July | 5 August | 5 November |
| 6 July to 5 October | 5 November | 5 February |
| 6 October to 5 January | 5 February | 5 May |
| 6 January to 5 April | 5 May | 5 August |

## Who goes on it: 23 workers, nine lines

A six-consultant agency had 23 people out on assignment between 6 July and 5 October 2026.

| Workers | How they were paid | On the report | Reason code |
|---|---|---|---|
| 14 | The agency's own payroll, under PAYE | No | None |
| 5 | Through their own limited companies | Yes, with payment details | D |
| 3 | Through an umbrella company that ran PAYE | Yes, without payment details | F |
| 1 | As a sole trader | Yes, with payment details | A |

The four rows add up to 23. The report has nine lines, from the last three rows. The 14 on the agency's payroll already reach HMRC through its payroll submissions.

HMRC's template has six reason codes for why PAYE was not operated. A is a self-employed sole trader, B a partnership, C a limited liability partnership, D a limited company including a personal service company, E a non-UK engagement, and F means another party operated PAYE.

The amount for each worker is the total you paid for their services in the period, including expenses and VAT. If one contractor's company was paid £28,800 including VAT over the quarter, the entry is 28800.00 with no comma, GBP, and Y in the VAT column.

## What to collect for each worker

| For | You need |
|---|---|
| Every worker | Full name, address and postcode; National Insurance number, or date of birth and gender if they have none; start date of the engagement, and the end date if it ended in the period |
| Codes A, B and C | The unique taxpayer reference, which is 10 numbers |
| Codes A to E | Amount paid, currency, whether it includes VAT, and the name and address of the party you paid |
| Code D | The Companies House registration number |
| Code F | No payment details |

## The email to send this week

To a contractor's limited company:

> Subject: Details needed for our HMRC report, 6 July to 5 October 2026
>
> Dear [name],
>
> We supplied [worker]'s services to [client] through [company] between 6 July and 5 October 2026 and did not operate PAYE on the payments. HMRC requires us to report the engagement by 5 November 2026.
>
> Please send me by [date, two weeks after the quarter ends]:
>
> - the worker's full name, home address and postcode
> - their National Insurance number, or their date of birth and gender if they have none
> - the company's registered name, address and Companies House registration number
> - whether VAT was charged on the invoices for this period
>
> We keep what you send for at least three years, as HMRC requires, as evidence of why PAYE was not operated.
>
> Kind regards

To an umbrella company the request changes. Ask for the worker's full name, address and National Insurance number, and for written confirmation that the umbrella operated PAYE on every payment to the worker in the period. That confirmation is your evidence for code F.

## How to send it

1. Download a fresh copy of HMRC's template for each report. It must stay one sheet, as an ODS or CSV file under 20MB, with no password.
2. Sign in to the online service. You need a Government Gateway organisation account, your employer PAYE reference and your Accounts Office reference.
3. Upload the file and use the check for formatting errors before you accept and send.
4. Replace the report if you find a mistake. You have until the next period's deadline, which for this report is 5 February 2027.

You can upload as often as you like in the quarter.

## The penalties

A late report is penalised automatically, and the amount depends on how many you have missed in 12 months:

| Offence in 12 months | Penalty |
|---|---|
| First | £250 |
| Second | £500 |
| Third and later | £1,000 |

An agency that misses 5 November, 5 February and 5 May pays £250, £500 and £1,000, which is £1,750. After 12 months with nothing late, the next one counts as a first offence again. Where reports keep failing to arrive, HMRC says the penalty can be up to £600 for every day.

An incomplete report counts as an incorrect one, and those penalties are set case by case. HMRC's manual puts the maximum at £3,000 for incorrect information given fraudulently or negligently. HMRC says it takes into account whether you replaced a wrong report before the next deadline without being asked. There is a right of appeal, using an online form.

## What to keep

Keep, for at least three years, the documents that show who was paid, how you worked out each amount and why you did not operate PAYE. For limited company contractors that file sits beside the status paperwork in the [IR35 guide for agencies](https://aeolookup.com/recruitment/ir35-recruitment-agencies-fee-payer-umbrella-liability/). For umbrella workers it sits beside the longer [Key Information Document](https://aeolookup.com/recruitment/key-information-document-agency-workers-template-what-to-include/) they are given.

This page is general information, not tax advice.

## Short answers from this page

**When is the next employment intermediary report due at HMRC and what is the penalty for missing it?** The report for 6 July to 5 October 2026 is due by 5 November 2026. A late report brings an automatic penalty of £250 for a first offence, £500 for a second and £1,000 for a third or later one within 12 months. Continued failure can cost up to £600 a day.

**Which workers does a recruitment agency put on its employment intermediary report?** Every worker it supplied to a client and paid without operating PAYE: limited company contractors (code D, with payment details and the Companies House number), sole traders and partnerships (with a unique taxpayer reference) and umbrella workers (code F, no payment details). Temps on the agency's own PAYE payroll are left off.

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General information for UK small firms, not legal, tax or financial advice.
