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Off-payroll working reforms: review of implementation announced

Off-payroll working reforms: review of implementatio

The government will review how the off-payroll working reforms will be implemented, but the go live date of 6 April remains.


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What has happened?

In a welcome development, on 7 January the Government announced a review of how the April 2020 off-payroll working reforms are to be implemented.

This will gather views and evidence from affected individuals and businesses with the aim of ensuring a smooth introduction of the new regime.

The review will conclude by mid-February (i.e. prior to the Budget on 11 March).

There is currently no suggestion that introduction of the off-payroll working reforms will be deferred, and organisations should therefore continue with their current plans for implementation with effect from 6 April.

What will the review involve?

In summary, the review will involve:

  • Roundtable discussions with representative stakeholders to ensure that the new regime is introduced with as little disruption as possible;
  • Further analysis of the public sector’s experience of implementing the 2017 public sector reforms in order to benefit from key learnings;
  • Evaluation of HMRC’s enhanced Check Employment Status for Tax (CEST) online tool; and
  • Consideration of any further steps the government can take to assist businesses determine whether engagements fall within ‘IR35’.

The Government also confirmed that HMRC will continue to develop its programme of education and support activities relating to implementation of the new rules.

What happens now?

Affected organisations should monitor how the government’s review progresses and ensure that their views feed into that process – if you have any points that you would like to raise please feed them through to us and we will raise them with HMRC.

However, as noted above, there is currently no suggestion that implementation of the off-payroll working reforms will be deferred.

Organisations should therefore continue to prepare for implementation with effect from 6 April.

You can keep up to date with developments on off-payroll working reform through KPMG’s Employers’ Club.

If you would like to talk through the implications of the review – including any views you would like us to feed into the review on your behalf – or what the off-payroll working reforms mean for your organisation more generally, please get in touch with your usual KPMG contact or email

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