CIPP survey off payroll working rules from April 2020

13 May 2019

The CIPP policy team have produced a survey to collect views about the proposed rules for operating off-payroll working as from April 2020, the survey responses together with anecdotal evidence provided at the Policy think tank roundtable will support the CIPP written response.




The rules will apply to medium and large organisations in the private sector and any changes to the earlier reforms currently in operation within the public sector will also be updated to ensure consistency across sectors.


Intermediaries legislation (commonly referred to as IR35) was introduced in 2000 as a method of subjecting the pay of individuals to PAYE Income Tax and Class 1 NIC who would, if not for the intermediary they were working through, be employees.


The responsibility for assessing each contract of work lay with the individual working through the intermediary. An Intermediary could be the Personal Service Company (PSC) of the individual delivering the work, but could also be, another person or a partnership – the key issue being that they would be an employee if they were not working through an intermediary.


 In 2017, legislation in this space was introduced for individuals working via an intermediary for a public sector body which placed responsibility for assessing the contract of these workers on the fee payer. Referred to as off-payroll working, it was widely believed that this would also be extended to private sector engagements at some point.




  • Defining the scope of the reform
  • Information requirements
  • Determining the correct status
  • Pension contributions
  • Education and support

Whilst we have provided a small amount of information within each survey section we would strongly recommend that you read the consultation document or have it alongside you to refer to as you proceed through the survey.


HMRC have also published some early information to help affected organisations begin to prepare for change and one of the suggestions is to ‘Put processes in place to determine if the off-payroll rules apply to future engagements. These might include who in your organisation should make a determination and how payments will be made to contractors within the off-payroll rules.


We know from talking to our public sector members that good communications between affected departments is vital to the successful delivery of the reforms and you may find a combined response to this survey helpful as many of the questions address areas of responsibility that might not be relevant to your day to day operations.


Thank you in advance for your responses to this survey which will close on 17 May 2019.