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How to verify subcontractors before making payments under the Construction Industry Scheme. Contractors must verify every new subcontractor with HMRC to determine the correct deduction rate and avoid penalties.
You must check every new subcontractor's tax status with HMRC before paying them under the Construction Industry Scheme (CIS). This tells you whether to deduct 20%, 30% or nothing from their payment. If you do not check, you must deduct 30% and could face penalties.
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Before you pay a subcontractor for construction work, you must verify their CIS status with HMRC. This tells you whether they are registered for the Construction Industry Scheme and what rate of tax to deduct from their payment.
Verification is not optional. If you pay a subcontractor without verifying them first, you will apply the wrong deduction rate and may face penalties from HMRC.
The verification process serves two purposes:
Without verification, you must apply the highest rate (30%), which means your subcontractor receives less money and has to reclaim the difference through their tax return.
You must verify a subcontractor in two situations:
Once verified, a subcontractor remains valid as long as you continue to include them on at least one CIS return within a rolling period of the current plus previous 2 tax years.
When you verify a subcontractor, HMRC will return one of three results:
This is the most common result. The subcontractor is registered for CIS and you must deduct 20% from the labour element of their payment. This is the standard rate for registered subcontractors without gross payment status.
The subcontractor has been granted gross payment status by HMRC. You pay them the full amount with no deductions. They account for their own tax through Self Assessment or Corporation Tax.
Either the subcontractor is not registered for CIS, or the details you provided do not match HMRC records. You must deduct 30% from the labour element. If verification failed because of mismatched details, ask the subcontractor to check their records with HMRC and verify again once corrected.
Failing to verify subcontractors before payment is a breach of CIS rules. HMRC expects contractors to complete verification for every new subcontractor and can impose penalties for non-compliance.
The consequences include:
You must keep verification records for at least 3 years after the end of the tax year they relate to. HMRC can ask to see these records at any time.
For each subcontractor you verify, retain:
Keep records in a format you can produce if HMRC asks - either paper files or electronic records. Many contractors use accounting or CIS software that stores verification details automatically. If storing electronically, ensure you can access records for at least 3 years.
The information you need to verify a subcontractor depends on their business type. Details must match HMRC records exactly - even minor differences can cause verification to fail.
Tip: Ask subcontractors to provide their details in writing and confirm the exact format used on their HMRC records. Common issues include abbreviations (such as 'Ltd' versus 'Limited') or middle names.
The HMRC online service allows you to verify up to 50 subcontractors. If you work with more than 50, you must use commercial CIS software.
Benefits of commercial software include:
HMRC publishes a list of approved CIS software providers. Your accountant or bookkeeper may already use software that handles CIS verification.
Request the subcontractor's UTR, National Insurance number (or Company Registration Number for companies), and confirm the exact name registered with HMRC.
Sign in to the Government Gateway and use the CIS online service. Enter details exactly as the subcontractor provided them.
HMRC will provide a verification number. Record this along with the date and deduction rate for your CIS records.
Use the rate HMRC confirms - 0% for gross, 20% for registered, or 30% for unregistered or unmatched.
When you report payments to the subcontractor on your CIS monthly return, include the verification number.
If HMRC cannot match the subcontractor's details, verification will fail and you will receive a 30% deduction instruction.
In the meantime, you must apply the 30% rate. If verification later succeeds at 20% or 0%, you cannot retrospectively change previous payments - the subcontractor reclaims the difference through their tax return.
Every CIS contractor must verify subcontractors before first payment. This applies whether you are a main contractor, principal contractor, or deemed contractor (spending over 3 million pounds on construction operations in any rolling 12-month period).
The verification requirement is set out in the Finance Act 2004 and CIS Regulations 2005. There is no exemption for small contractors or occasional payments.