An intermediary is any person who makes arrangements for an individual to work for a third party or be paid by the intermediary for work done for a third party. An employment intermediary is also commonly referred to as an agency.


There are new requirements to report to HMRC any workers supplied to clients where PAYE has not been operated. There is not necessarily any problem. HMRC list legitimate reasons for why PAYE has not been applied. The requirement is to disclose the workers and let HMRC why PAYE has not been applied.

This will apply to you if you supply any worker (other than yourself) to any client and the worker is not paid by you through PAYE. This includes workers that are operating through their own limited company.

If you are a one-person limited company that only supplies clients with your own services, then this does not apply to you.

Also if you are providing a complete service to a client (rather than “providing a worker’s services to a client”) then this will not apply to that situation.

If you do need to submit a report then the deadlines for doing so are as follows:

Reporting period Deadline date
6 April to 5 July 05-Aug
6 July to 5 October 05-Nov
6 October to 5 January 05-Feb
6 January to 5 April 05-May


If the reports at not filed by these dates then HMRC may raise penalties.


Full information on this can be found on HMRC website here.


If you do supply any workers to clients that are not paid through PAYE by you (for any reason) or have any concerns please contact Green Accountancy.