A number of different people across a range of departments will likely be involved in ensuring IR35 compliance, but their training needs will widely differ, depending on their role – whether that’s making the status determinations, or passing the decision down the recruitment supply chain. 

Why IR35 training is vital 

At its core, IR35 aims to identify disguised employees, those working as external contractors but operating in the same way as an employee. The distinction is vital, as it affects how these individuals are taxed and how companies account for them. Failure to comply with IR35 can lead to severe financial penalties and reputational damage, making it a significant risk area for businesses. 

IR35 training needs to both educate participants at the level of detail and knowledge they need to perform their individual roles, as well as clearly define internal processes they are expected to follow. This variability is precisely why bespoke IR35 training is crucial. A tailored training programme can address the unique ways in which IR35 affects a business, taking into consideration its specific hiring practices and contractor engagements. 

The importance of tailored IR35 training becomes even more pronounced when we consider the varied roles within an organisation and their respective responsibilities towards IR35 compliance. 

IR35 training for Hiring Managers  

Often at the frontline of engaging contractors, they need training that equips them with the skills to identify when a role might fall inside IR35 and understand the implications of these decisions. Being able to accurately assess contract roles from the outset and use assessment tools such as HMRC’s Check Employment Status for Tax (CEST), can significantly mitigate the risk of non-compliance. 

IR35 training for Directors and senior management 

These stakeholders play a pivotal role in setting the tone and governance around IR35 compliance. Training for this group needs to underscore the financial and reputational risks associated with IR35, share relevant case law, and ensure they have the knowledge to oversee compliant practices. As well as looking at how the business can embed a culture of compliance within the organisation. 

IR35 training for HR and Talent Acquisition teams 

These departments often form the backbone of implementing IR35 compliant hiring practices. Their training should focus on the procedural aspects, including the checks and balances needed to ensure IR35 has been managed accurately ahead of onboarding. They’ll also need a clear understanding of the status disagreement process and how IR35 compliance is documented, should HMRC look for evidence that reasonable care has been taken to adhere to the legislation. 

Getting IR35 training right 

Given the complexities and evolving nature of IR35 legislation, engaging with an external IR35 specialist partner offers numerous benefits. These experts provide a depth of knowledge and experience that can be invaluable in navigating the intricacies of compliance. They can offer bespoke training, tailored specifically to the needs of your organisation and stakeholders, and ensure that your teams are up to date with the latest legislative developments. Moreover, specialist partners can provide ongoing support, helping to review contracts and working practices, thereby ensuring that your business remains compliant over time. 

Our Linx IR35 experts work with companies to identify their training needs, before creating programmes that are driven by your internal processes, combined with their in-depth knowledge of the off-payroll working legislation. They also carefully consider how that training should be delivered to best engage each audience, from online training resources to face-to-face workshops, blending the right learning techniques to ensure comprehensive training and mitigate the risk of non-compliance. 

The post Not all IR35 training is equal  appeared first on Linx.

Understanding IR35 in the engineering sector 

For those not up to speed, IR35 is HMRC’s off-payroll working legislation that was initially rolled out to the public sector, before being extended to the private sector in recent years. 

Put simply, it was devised to tackle tax avoidance practices, providing clear differentiation on what constitutes off-payroll working through a Personal Service Company (PSC), and what indicates deemed employment. Deemed employment is HMRC’s term for a contingent worker operating through a PSC who’s working practices are too similar to directly-hired personnel, deeming them employed for the purpose of tax and National Insurance deductions. Those contingent workers who fall out of scope of IR35, are responsible for managing their own tax implications through their PSC. 

What does this mean for engineering companies? 

When IR35 was first extended to the private sector there was lots of talk of reducing the talent pool, because it would deter candidates from opting to work as external contractors.  

There are several key things to remember however: 

• IR35 only applies to contingent workers engaged through Personal Service Companies, Pay As You Earn and Umbrella contractors are not required to adhere to IR35 

• IR35 assessments, known as Status Determination Statements, need to be completed for each assignment, to determine if the off-payroll working rules apply – not all assignment may be in scope 

• Where Status Determination Statements indicate the assignment is in scope, the contingent worker can still operate through their PSC by opting for deemed payments to manage their tax and National Insurance implications 

• The working practices and remit the contingent worker will have to complete the work, will play a significant factor in their IR35 status determination 

What’s clear to see since the private sector implementation is that where niche and specialist skills are required that engineering companies do not have in-house, the engagement of PSC contingent workers is still paramount to project delivery. However, their working practices need to evidence that they are working externally to the client they are delivering the work to, and they must be given the responsibility and remit to complete the work without unnecessary direction, supervision or control. Without a detailed understanding of how IR35 is assessed, engineering companies risk losing access to the crucial specialist skills they need. 

Managing the risks of IR35 non-compliance 

Done correctly, engineering companies shouldn’t see IR35 as an administrative burden, provided they have the right support in place to help them manage compliance. 

Internal audits can help to identify any high-risk areas, as well as undertaking a review of contractual arrangements with agencies to ensure processes remain in line with your company’s IR35 strategy. Evaluation of existing IR35 training for staff can also help to identify any areas of concern that need to be addressed, whilst checking training follows the latest IR35 insight from HMRC. 

Our experts have extensive knowledge of IR35 in the engineering sector, teamed with insight on how best to manage the off-payroll working rules in large organisations with multiple recruitment suppliers. They operate as the single point of contact to manage IR35 compliance, reviewing internal processes to ensure they will stand up to scrutiny, whilst ensuring adequate training is given to key stakeholders involved in status determinations. How adept the recruitment supply chain is when managing in and out of scope decisions also plays a crucial role in IR35 compliance, which is why our team extends their support to suppliers as well as internal stakeholders. 

Retaining access to specialist skills 

A company’s approach to IR35 needs to carefully balance the need to adhere to HMRC’s off-payroll working rules and mitigate risk, whilst ensuring access to the skills needed to win and deliver engineering projects. 

When HMRC first announced that IR35 would be extended to the private sector, some businesses took a blanket decision to stop using Personal Services Companies. It was a stance that removed the risk of non-compliance but also drastically reduced their access to skills and specialist talent.  

Our Linx team works with companies to understand their contracting requirements, to ensure the best engagement solution is put in place to secure the right talent needed. This includes the use of Statement of Work models to secure skills on a project deliverables basis, with a clear contract in place to indicate milestones and payments. 

The post Managing IR35 compliance in the engineering sector  appeared first on Linx.

Here are the seven main ways you can reduce the IR35 administration load, and how Linx can support you every step of the way. 

Implement a centralised IR35 process 

One of the biggest challenges businesses face is inconsistency. When different departments or hiring managers approach IR35 status determination assessments in different ways, mistakes are inevitable, whilst also increasing the likelihood of disagreement challenges. A centralised IR35 process ensures everyone follows the same procedure – using standard tools, templates, and documentation methods. 

How Linx helps: We can design, implement and operate your central IR35 process, ensuring robust governance and a consistent compliance approach across your organisation. For companies with multiple divisions or business units, the need to have a central process is even more crucial. 

Appoint IR35 governance 

IR35 compliance is not something that can be tackled ad hoc, it requires dedicated oversight. Appointing an IR35 lead or small governance team ensures the business has clear accountability for policy, process management, and issue resolution. Those colleagues making Status Determination Statement assessments will also have a clear point of escalation if they need further support. 

How Linx helps: If you don’t have the resource in-house, Linx can act as your outsourced IR35 governance partner – managing compliance on your behalf, monitoring updates, and ensuring best practice is upheld. 

Train hiring managers and internal teams 

Many of the risks around IR35 arise from misunderstandings or lack of awareness — especially among hiring managers. Without proper training, they may inadvertently create contracts or working conditions that contradict a status determination. Where their knowledge of IR35 is not up to speed, companies also carry the risk that in and out of scope IR35 determinations may not be accurate. 

How Linx helps: We deliver tailored IR35 training for hiring teams, procurement, HR, and talent acquisition stakeholders – helping them understand their responsibilities and reduce risk through everyday actions. 

Regularly review and refresh determinations 

IR35 isn’t a one-off box-ticking exercise. Contractors’ roles, responsibilities, and working practices often change over time. If determinations aren’t periodically reviewed and updated, businesses risk non-compliance – even with well-intentioned processes in place. 

How Linx helps: We maintain regular touchpoints to review and refresh status determinations, keeping your compliance up to date and removing the burden of constant monitoring from your internal teams. 

Maintain well-documented audit trails 

HMRC expects businesses to provide clear, accurate records of their IR35 assessments and decisions to demonstrate they have taken reasonable care. That means securely storing contracts, status determinations, communication trails, and the rationale behind each decision. Add in a recruitment supply chain who engage the PSC contingent workers on your behalf, and the task becomes even more complex. 

How Linx helps: Linx work with organisations to devise supply chain compliance audits, to ensure status determinations have been accurately passed down and all the necessary paperwork is in place to satisfy HMRC’s reporting requirements – making it easy to evidence compliance if challenged. 

Stay informed on legal and HMRC updates 

IR35 is a moving target. With legal cases setting new precedents and HMRC periodically adjusting guidance, it’s crucial that businesses stay updated. But monitoring policy changes and adapting processes accordingly adds another layer of administration. 

How Linx helps: We stay on top of every IR35 development, so you don’t have to. Our team ensures your approach is always aligned with the latest legal and regulatory expectations and we maintain regular communication with our clients to notify them of any changes. 

Engage an IR35 expert 

The simplest way to reduce the administrative burden of IR35? Hand it over to the experts. Managing compliance internally requires time, legal understanding, and resourcing that many businesses simply don’t have. It also requires colleagues to become IR35 experts, whilst continuing to perform their other responsibilities. 

How Linx helps: We work with organisations across the UK to support them with IR35. From managing assessments, to auditing their supply chain and identifying non-compliance risks in internal processes, we’re able to share the latest IR35 insight to help your business manage IR35. Our team are committed to ensuring your organisation has the right information to make informed decisions on IR35.  

The post 7 ways to manage the administrative burden of IR35  appeared first on Linx.

In our latest blog we take a more detailed look into status determinations. 

What is an IR35 determination? 

In short, it’s the process organisations are required to go through to determine the tax status of workers who are engaged through a Personal Service Company (PSC). 

HMRC first introduced the need to perform IR35 determination checks on off-payroll workers in the public sector, before extending the legislation to the private sector. Its purpose many agree was to manage tax avoidance practices and make clear differentiations between those workers who are operating independently as an external PSC worker. As opposed to those who are operating too similarly to directly engaged permanent workers. The biggest difference between them is how HMRC collect tax on their earnings. 

What is a determination status? 

The determination status, derived through a Status Determination Statement (SDS), is the document that details each worker’s employment status for their assignment. An SDS should detail one of two outcomes: in scope of IR35 or out of scope. 

In scope means that IR35 does apply to the worker’s assignment, so tax and National Insurance Contributions need to be deducted from their earnings, known as Deemed Payment. Out of scope on the other hand indicates that the worker is operating outside of the off-payroll working legislation, so IR35 does not apply, and they are responsible for meeting their tax implications through their Personal Service Company. 

Who is responsible for IR35 determinations? 

The End Client is responsible for making the IR35 determination, by issuing an SDS to all parties involved in the contingent worker’s engagement. 

For organisations who partner with recruitment agencies to supply contingent workers, it’s critical that IR35 determinations are still made by the End Client, the company which the worker is delivering the work to. Whilst agencies might be able to help share insight into working practices, businesses need transparent processes in place to demonstrate that reasonable care has been taking to ensure the accuracy of status determinations, which may need to be evidenced should HMRC wish to open an investigation. 

The End Client should have a formal disagreement process in place, should the worker or any stakeholders in their engagement chain wish to challenge the determination. Companies have 45 days to respond to the dispute, detailing their reasoning behind the outcome. The original status must remain in place during the investigation period, and if the review determines a different outcome and new SDS must be created and shared with all parties. 

Is there an IR35 determination calculator? 

HMRC developed a digital tool, Check Employment Status For Tax (CEST), which is free for organisations to use to make status determinations. Users answer a series of questions around how the worker is engaged, before the tool outputs it’s determination: in scope, out of scope or unable to determine. Where the tool is unable to determine a clear IR35 status, further review of working practices will be required to identify areas that may be unclear. 

Other tools are available in the market and HMRC do not mandate the use of CEST, however they say they will stand by its outcomes provided the tool has been used correctly and honestly. 

What are the three key tests for IR35? 

Tools like CEST assess a range of areas to determine whether HMRC believe IR35 applies to the worker, including three key areas. 

Substitution 

The concept refers to the structure and nature of a working relationship between an off-payroll worker and their End Client. The right to substitution is one of the key tests in determining an IR35 status. It refers to whether a PSC worker has the genuine right to send someone else to do their work in their place. If the worker is free to provide a substitute with similar skills and technical knowledge, and the client would accept this without restriction, it indicates a level of independence typical of self-employment. Alternatively, if the client requires the contractor to personally carry out the work, this may point towards an employment relationship – potentially bringing the engagement inside IR35. Right to substitution helps determine whether the worker is genuinely self-employed or effectively operating as an employee in disguise, a practice known as Disguised Employment. 

Control 

Control is a fundamental test in determining whether the PSC worker falls inside or outside IR35. It looks at how much direction the client has over what work is done, how it’s done, and when or where it’s carried out. If the client exercises a high level of control and supervision, like they would an employee, it suggests the worker is not truly independent. Genuine PSC workers typically have autonomy over their work, which can help support an outside IR35 status. Therefore, assessing control is crucial in identifying the true nature of the working relationship. 

Mutuality of obligation 

Mutuality of obligation (often referred to as MOO) is another key factor in determining the IR35 status of an off-payroll worker. It refers to whether the client is obliged to offer work and whether the worker is obliged to accept it. In a typical employment relationship, there is an ongoing expectation of work and payment. However, a genuine contractor relationship should lack this mutual obligation – work is agreed on a project-by-project basis, with no guarantee of future engagement from both parties. Crucially as well, the worker should not feel they are obligated to accept additional work the client requests. The presence or absence of MOO helps distinguish between employment and self-employment, making it a crucial part of any IR35 assessment. 

What are the red flags for iR35? 

Fundamentally, HMRC’s legislation is designed to identify those workers who are acting in the same way as an employee of the business but work through their own PSC and as such do not pay tax and National Insurance Contributions in the same way as Pay As You Earn employees do. 

As a business it’s crucial that the engagement terms of your off-payroll workers, and their working practices have clear differentiation between how employees and PSC workers are engaged. 

Income reliance from one client 

Red flags can include workers who obtain a large percentage of their income from one client, potentially indicating that there is an agreement, whether that be formal or informal, that they will be secured to work back-to-back on projects. Whilst this might be due to the specialist services the worker provides and not because there is mutuality of obligation, none the less it’s important to have clear processes in place for repeat assignments, and an individual SDS for each. 

Part and parcel 

Part and parcel is a key measure for HMRC’s determination of IR35 status, where it looks for evidence that the PSC worker has become integrated into the business. Factor such as whether they have their own desk, security pass and access to subsidised canteen facilities need to be considered. Together with indicators such as the worker using a company email address or being asked to manage directly engaged permanent staff. Access levels to areas of the building or computer databases also needs to be considered, would a company grant permission for external parties to access confidential information without supervision? 

Financial Risk 

How much risk financially the worker takes on may be a red flag, in particular where they carry very little risk. If they are providing their skills to the company through their PSC company, this should indicate a contract of service not employment. As such it’s expected that the PSC company will carry some financial risk, such as being paid a fixed price for the work they deliver – regardless of how long it takes them. If it takes them longer to complete the work, this would not automatically allow them to bill the client more. Similarly, in stances where the work standard is not adequate, the PSC company would typically be expected to rectify this at their own cost, indicating the financial risk they have taken on. 

How long does an IR35 status determination last? 

The expiry length of an IR35 status determination can be a grey area. Whilst it is intended for the length of the engagement, longer assignments may require additional scrutiny. 

The SDS provides a snapshot of what the engagement looks like ahead of the assignment starting. Once the contingent worker commences, working practices may defer to those expected, even where the assessment has been made in good faith. Another factor that may indicate that further review is needed, is when the remit of the worker changes in line with the needs of the project. That’s not unusual, but it will require a new SDS to be created where there are material changes to how the worker is engaged. 

It’s also best practice to reissue Status Determination Statements when assignments have been active for 12 months or more. Undertaking reassessments ensure that key measures such as part and parcel haven’t become difficult to clearly evaluate over time. Where the new SDS indicates a change in their determination, this needs to be passed to the worker and down the chain of engagement. 

For organisations who engage hundreds of off-payroll workers this need to reevaluate status determinations can be highly administrative and time-consuming. That’s why Linx’s IR35 team works with clients to manage this process on their behalf, ensuring the correct checks and measures are in place to provide them with meaningful insight to make informed changes and future decisions around IR35. 

How can businesses ensure their status determinations are robust? 

We’d always recommend partnering with an external consultancy to provide independent and impartial oversight into your IR35 processes, including how you perform status determinations. 

This includes reviewing the staff training your business provides, to ensure those involved in making status determinations have the right level of knowledge about IR35. How IR35 is managed within your recruitment supply chain is also a key area of concern for our experienced team, who’ll work with you to develop tailored supply chain audits if needed to actively manage the risk of non-compliance. 

The post IR35: what’s in a determination?  appeared first on Linx.

Accolades like this wouldn’t be possible without the support of our teams, who shared their feedback on working in the NRL Group anonymously with Great Place To Work® last year. 97% of them agreed that they thought the NRL Group was a great place to work when surveyed, earning us the official certification.

Diversity and inclusion are deeply rooted within our culture, and we’re committed to providing new job opportunities and career development support to women across our business. So, we couldn’t think of a better way to celebrate our latest accolade, than to shine a spotlight on just some of our wonderful colleagues working across our teams.

Lisa Jackson, Divisional Manager at NRL’s Sunderland recruitment branch

We’re privileged to have had Lisa in our Sunderland team for 22 years and are pleased to have seen her career develop over this time to her current role overseeing the strategic growth of the branch, during an extremely busy and exciting time.

“Throughout my time at NRL, I’ve been fortunate to work alongside some incredibly talented women whose leadership and mentorship have helped shape my career.  They have pushed me to back myself and lead with confidence, to really challenge myself and use my voice in high-pressured, often male dominated situations.  It’s something I’m really passionate about passing on and supporting others with as they grow in their own careers.

Selina Benton, Operations Manager for NRL’s Rail contracting business

Having worked in NRL’s Rail business for more than 10 years, there isn’t a single thing Selina doesn’t know about our rail maintenance and contracting services. Historically male-dominated, it’s refreshing to see the sector advocating for a better gender balance.

“I can honestly say through my own experience at NRL, roles are filled based on skill, not gender, which is great to see and rewarding as an employee who’s progressed her own career with the company. The National Skills Academy for Rail (NSAR) Workforce Study 2024 highlighted that gender diversity has risen to 17.4%, indicating the rail industry is moving in the right direction. But real progress requires equal access to jobs and training, inclusive growth, and shared success. Career advancement should be driven by experience, proficiency, and opportunity – not gender bias.”

Martha Njue, International Compliance Manager for NRL’s recruitment business

Our international recruitment and global mobilisation capability has grown significantly since Martha’s first day in the office 17 years ago.

“It has been an incredibly uplifting journey to witness the growth of NRL’s International services – from a small team of 3 people to two dynamic teams; International Compliance and International Recruitment, comprising of 6 talented ladies and 6 dedicated gentlemen.

With our operations now spanning multiple regions across the globe, I feel truly fortunate to be part of NRL. Over the past 17 years, I’ve been supported and empowered to grow—from starting as a junior Payroll Assistant to becoming an Office Manager and now serving as the International Compliance Manager. NRL has not only fostered my professional development but has also exemplified what it means to be a workplace that champions women and nurtures talent.”

Natalie Baines, Operations Manager for our Linx business

Within our Linx business we help companies gain better oversight and management of their contingent labour workforce and recruitment supply chain, so it’s always busy for Operations Manager Natalie. Joining the business in 2017, she’s been pivotal in evolving our client services.

“Reflecting on my journey since joining Linx, I’m proud of the growth I’ve experienced both personally and professionally. Over the past eight years, I’ve had the opportunity to develop my skills, broaden my experience and contribute to key areas of business growth, all of which have played a significant role in building my confidence and shaping my career.”

Taylor Gibbons, Technical Assistant/NDT Technician for NRL’s Non-Destructive Testing business

When Taylor joined NRL’s NDT business last year it marked an important milestone, as we look at how we can attract more women into a male-dominated discipline.

“Joining NRL Group has been an exciting step in my career, offering strong professional support and opportunities for growth. As a Radiographer entering a male-dominated sector, I have been encouraged by the inclusive environment and the respect shown for my skills and contributions from day one.”

Jessica Neil, Compliance and Administration Assistant at NRL’s Wigan recruitment branch

Jessica joined NRL’s Wigan team through an apprenticeship opportunity 4 years ago, and we’re pleased to see how much her knowledge and skills have grown over the years.

“When I joined NRL’s Wigan team through an apprenticeship opportunity, I received a great deal of support throughout my learning. I was given dedicated time to revise for exams and complete my Level 3 Business Administration course work, with everyone in the team invested in my learning. Since then, I’ve continued to be given more opportunities to learn new skills and extend my knowledge, including getting more involved with the facilities management side of our operations, and have been encouraged to participate in personal effectiveness training, which has been extremely beneficial.”

Tiffanie Harding, Recruitment Consultant in NRL’s Teesside branch

When Tiffanie joined NRL’s North East operations in 2023, fellow colleagues were only too happy to share their knowledge and help her progress.

“As someone new to the recruitment industry, it is incredibly inspiring to start my journey at a company recognised as one of the UK’s best workplaces for women. In my 2 years recruiting in the engineering sector – a traditionally male-dominated field – I’ve seen first-hand how our company creates a truly inclusive environment where everyone can excel.”

Want to find out more about our UK’s Best Workplaces for Women™ listing?

You can read our full release below.

The post Celebrating being one of the UK’s Best Workplaces for Women™ appeared first on Linx.

The UK’s Best Workplaces for Women™ 2025 List, celebrates those businesses whose own female colleagues rated them outstanding, following anonymous feedback shared through Great Place To Work^®. The NRL Group have been recognised in position 45 for medium-sized organisations, reflecting their ongoing efforts to build a workplace culture rooted in respect, equity, and opportunity.

With 97% of UK-based colleagues agreeing the company is a great employer, survey responses earned the company the official Great Place To Work^® certification in 2024. When analysed on a demographic level, 97% of female employees felt they were treated as full members of the company, regardless of their position. 100% said they were given the resources and equipment to effectively work, and 97% felt their work contributed to achieving the company’s mission.

It’s the fifth Best Workplaces award the company has been presented with, having previously been recognised for their commitment to career development and wellbeing, as well as being named one of the UK’s Best Workplaces for 2025.

NRL Group CEO David Redmayne reflects on the latest accolade.

“We’re incredibly proud to be recognised as one of the UK’s Best Workplaces™ for Women, this achievement reflects our long-standing commitment to creating an inclusive environment where every woman feels empowered to grow, lead, and succeed.

Across our teams we’ve had the privilege of supporting women to progress in their careers, and many who joined in junior positions are now leading the delivery of our recruitment, workforce and contracting services.”

With small, medium, large and super large sized organisation featured on this year’s list, each share a commitment to ensuring a meaningful balance of women and men across the organisation; removing barriers to women’s career advancement; and creating workplaces where all employees, regardless of gender, can flourish.

Benedict Gautrey, Managing Director of Great Place To Work UK added:

“This year’s UK’s Best Workplaces for Women list highlights organisations that are moving beyond good intentions and delivering real, measurable progress. These companies are dismantling outdated norms, prioritising women’s health, and building clear, supported pathways to leadership.

This recognition is driven by what matters most: the voices of women who work there. They’ve said, in their own words, that their workplace is one where they’re respected, empowered, and able to succeed.”

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Understanding the changes to CEST

Once the changes to CEST had been released, the industry opinion was that any updates were only cosmetic, with no fundamental change to the technical principles and underlying logic that determines the in or out of scope outcome.

One of the most recognisable updates is that the language has been simplified, designed to improve user experience and make answering the questions much easier.

The questions the CEST digital tool asks were originally designed to help End Clients determine the tax status of their off-payroll workers, and that’s certainly not changed with these minor updates.

CEST and Mutuality of Obligation

The biggest noticeable change to the questions, is around mutuality of obligation, posing the question ‘Do you have, or will there be, a contract in place?’. It’s an important addition however, as HMRC’s digital tool will not let you continue if you enter a no response. This, they say, is because there must be a contract in place between two parties in order to consider whether it is a self-employed or employed engagement. They detail that their definition of whether a contract is in existence is through one of two measures:

• The company engaging the workers has an obligation to pay then a wage or similar renumeration
• The worker is obliged to undertake their own work or skills.

HMRC guidance published on this topic, in their Employment Status Manual ESM11036, states that answering yes to the question will not impact the IR35 status determination.

The importance of CEST

HMRC has not mandated the compulsory use of CEST to make status determinations on the workers, however it has made it clear that it recommends its use. In the newly updated disclaimer at the start of the digital tool, it reconfirms that HMRC will stand by in and out of scope determinations the tool outputs, provided it has been used honestly.

Below we look at instances where HMRC will not uphold CEST outcomes:

• Actions that are deliberately intended to provide a certain result, what they call ‘contrived arrangements’
• Falsely answering questions about engagement terms, intentionally knowing they have been answered in a way that is not correct

When investigated, these would be used as evidence of deliberately attempting to misuse the tool, indicating non-compliance – something they say can attract higher penalties.

Using CEST to manage IR35 compliance

When we’re working with clients, we strongly recommend integrating HMRC’s CEST tool into status determination processes. Using CEST not only demonstrates that your business is taking reasonable care in assessing employment status, but it also provides a clear, auditable record of each determination.

Being able to evidence IR35 compliance through steps such as using HMRC’s digital tool is crucial for protecting your business and proactively managing risk.

There are several benefits to using the CEST tool:

• Shows that your IR35 decisions are based on HMRC’s own guidance, strengthening your compliance position.
• You can save and document each assessment, providing evidence of due diligence and responsible practice.
• You can leverage HMRC’s commitment to stand by CEST results, provided the tool is used honestly and accurately.

Making CEST a core part of your IR35 compliance strategy helps minimise risk and safeguard your business from potential penalties.

Managing the administrative burden that comes with IR35

From understanding the engagement terms of individual workers, to reviewing service agreements and the standard processes workers follow such as their working practices, IR35 can be difficult to manage. Add to that the additional complexity of managing your recruitment supply chain to ensure processes are being followed and deemed payments are in place for in scope workers, and it creates a heavy administrative burden for HR and talent acquisition teams.

To remain compliant with IR35 off-payroll working legislation however, regular check and measures need to be in place to ensure your current IR35 strategy is still correct. Key areas such as staff training also need to be reviewed to ensure those people making Status Determination Statements have adequate knowledge to accurately do so. Whilst periodical supply chain audits can help to identify areas of concern that need further development to protect your business from potential IR35 non-compliance.

These are all services our experienced IR35 team provide to our clients, and we’re always happy to chat to your business to discuss how we can support you.

The post Recent updates and changes to CEST appeared first on Linx.

When the IR35 off-payroll working legislation was extended to the Private Sector in 2021 businesses implemented new processes and procedures to meet IR35 requirements. A few years on, do these same practices still hold up? Are they effective for risk management? Would they stand up to robust scrutiny if required? 

In this comprehensive guide we’ll recap on what IR35 is, the implications for your business and the ongoing steps you should be taking to manage IR35 compliance. This includes: 

• Understanding the implications of IR35 for your business 

• Understanding your IR35 responsibilities as an End Client 

• Assessing and managing the risks associated with IR35 

• Developing an IR35 strategy that’s right for your business 

• Taking control of IR35 compliance across your supply chain 

• Benefits of working with an external consultancy for IR35 compliance 

Understanding the implications of IR35 for your business 

What is IR35? 

IR35, known as the off-payroll working rules, was introduced by HMRC to ensure that contingent workers pay the correct amount of tax and National Insurance. It affects individuals providing their services through Personal Service Companies (PSCs), which you may also see referred to as Limited Company contingent workers. The legislation aims to distinguish between genuine external contingent workers and ‘disguised employees’ — off-payroll workers who operate in a similar way to permanent workers but are engaged through their own business. 

To determine whether IR35 applies to a contingent worker, HMRC requires the end client, whom the worker is delivering their services to, completes a Status Determination Statement (SDS) – which declares whether they are in or out of scope for IR35. Put simply, in scope suggests their working practices are too like permanent members of staff, so IR35 applies, and tax and national insurance must be paid, known as a Deemed Payment. Out of scope determinations on the other hand have found that the working practices suggest the contingent worker is operating independently, so IR35 does not apply, and the worker is responsible for managing their own tax implications as a business owner. IR35 needs to be assessed for each assignment a contingent worker operating through a PSC undertakes, and where working practices change significantly and their responsibilities alter, a new SDS needs to be issued.  

To create Status Determination Statements HMRC recommends using their Check Employment Status for Tax (CEST) online tool, which had an update in April 2025. Other tools have been developed by companies offering IR35 support, and it’s important for businesses to make an informed decision about which they believe will provide the most accurate Status Determination Statements. It’s worth noting though, HMRC say they will stand by their CEST tool’s outcomes for tax purposes provided accurate information has been entered and it has been used in line with their guidance. 

Why IR35 compliance matters 

Taking a lenient approach to IR35 can lead to significant financial penalties, legal complications, and reputational damage. IR35 compliance shouldn’t be just about generating Status Determination Statements; it’s an ongoing effort that requires strategic direction and operational diligence. Adequate monitoring and robust compliance processes will reduce the potential risks of non-compliance, which can include back taxes, interest and fines. 

Reasonable care is also a significant measure for HMRC should they open an investigation into how IR35 is being managed within your business. They’ll want to see that steps have been taken to demonstrate that colleagues in your organisation have had training on IR35, processes you have in place in your HR and talent acquisition teams are effective in identifying in and out of scope assignments, and any recruitment suppliers you work with are implementing Status Determination Statements correctly. 

Understanding your IR35 responsibilities as an End Client 

The Basics of IR35 

IR35 is a piece of legislation designed to combat tax avoidance by contingent workers operating through Personal Service Companies (PSC). Where historically it was the PSC worker’s responsibility to determine their tax status for assignments they completed, IR35 has taken this responsibility away from the workers and moved it to the End Client, the company who the work is being delivered to.  This means that organisations now need a good understanding of working practices, how the relationship will work and who is responsible for what. For example, will the PSC worker be providing their own equipment, or will they be using the client’s tools? When it comes to annual leave, will the contingent worker be required to request permission from the client to take time off? 

Where contingent workers operate out of scope of IR35, they are deemed to be delivering a service to the End Client, how they deliver that service is for them to decide. This includes providing adequately trained substitutes to work on their behalf when they are unavailable or notifying the End Client when they will be on leave without needing permission first. Out of scope contingent workers will also typically deliver their services against pre-agreed milestones, where they are left to determine how best to complete the work, with little direction or control from the End Client.  

It’s important for organisations to understand how IR35 is assessed, to know the questions they need to be asking to make accurate Status Determination Statements. This may include looking at any changes they can make to working practices to help provide clear differentiation between in and out of scope assignments. For organisations working across various industry sectors, these processes might look very different depending on the security levels or regulatory requirements. 

Responsibilities of End Clients Under IR35 Legislation 

Once the End client has created the Status Determination Statement (SDS), they are required to pass it down the supply chain, to ensure all parties understand the outcome and can apply it to their contingent worker’s assignment. 

Should the worker, or anyone else in the chain such as the Fee Payer, wish to challenge the SDS a clear Status Disagreement Process needs to be put in place. The End Client must respond within 45 calendar days, and the existing in or out of scope determination will remain in place during the investigation period. Where the outcome of the review changes the IR35 status, a new SDS must be created and passed down to all parties in the supply chain. 

Assessing and managing the risks associated with IR35 

Identifying high-risk areas in your organisation 

Effective IR35 management begins with identifying areas within your organisation where non-compliance risks might reside. Companies that employ multiple contingent workers through various recruitment suppliers must scrutinise how their agencies are approaching IR35 as well as looking at internal processes. Does each party involved fully understand their responsibilities? How are IR35 assessments performed? What checks are in place? Are blanket decisions being taken on groups of workers operating in a similar way? Each assignment requires its own Status Determination Statement, but they can only be accurate when there is adequate training on IR35 and a solid understanding of working practices. 

Practical ways to mitigate IR35 risks 

Identifying any areas of concern can be difficult to spot when you’re in the day-to-day details, which is why we always recommend engaging an external consultancy to make an independent review of how IR35 is being managed within your business and any risks that need immediately addressing. 

Risk mitigation requires an IR35 review of current contracts and working practices with contingent workers as well as an audit of your recruitment supply chain. Documentation needs to reflect everyday processes and staff training needs to be evidenced to demonstrate reasonable care has been taken to manage IR35 within your organisation. 

Developing an IR35 Strategy that’s right for your business 

Internal processes: are they fit for purpose? 

Having robust internal processes means your business is better equipped to make accurate IR35 determinations. For IR35 compliance, it’s not just about having processes in place; it’s also about the clarity and consistency of those processes across all business units and supply chain stakeholders. 

Training and awareness for staff involved in IR35 

For HR, talent procurement teams, and hiring managers, understanding IR35 is fundamental to compliance. Linx provides IR35 compliance solutions that include comprehensive reviews of staff training, pinpointing knowledge gaps, and offering training programmes that elevate your team’s understanding and decision-making ability. 

Conducting supply chain audits 

Your recruitment supply chain is a critical element in ensuring IR35 compliance. Regular audits can identify conflicts, and highlight changes required to maintain IR35 compliance. 

Taking control of IR35 compliance across your supply chain 

For businesses who already have an IR35 strategy in place devised when the off-payroll working rules were extended to the Private Sector in 2021, it’s crucial to ensure this is still being actioned correctly and whether the approach continues to be right for your business. 

Changes within your business operations, functional departments and new personnel within your business or your supply chain, may have resulted in small changes to working practices and how existing IR35 processes are now being interpreted. That’s why we recommend undertaking periodical reviews of a company’s IR35 strategy, to ensure that what’s documented still reflects today’s operations. Changes in legislation also need to be monitored and, where appropriate, be reflected in processes and working practices, making it even more crucial to regularly review IR35 protocols. 

Benefits of working with an external consultancy for IR35 compliance 

Independent review and expert advice 

HMRC want to see that organisations have taken reasonable care to manage IR35 within their business, and that steps have been taken to understand the off-payroll working rules. Engaging an independent partner such as Linx, can allow businesses to gain wider industry knowledge and best practice, whilst securing the support of external experts who are best placed to review your IR35 strategy and identify areas of risk and non-compliance. 

Reducing the administrative burden 

Comprehensive audits of IR35 processes to assess the accuracy of Status Determination Statements and working practices can take up significant time, tying up internal resources on lengthy reviews. Extensive training is also required to ensure they can adequately assess processes and identify areas of non-conformance, which adds additional duties and responsibilities to often already busy HR and talent acquisition teams. 

Our role at Linx is to bring an independent perspective that can proactively manage IR35 compliance whilst alleviating the administrative burden. Through independent IR35 reviews and sharing of best practice, we can help your business address any compliance challenges with strategies that are proven. 

Tailored services around your business needs 

Our Linx IR35 specialists don’t just provide a one-size-fits-all solution; they offer a range of services based on the needs of our clients. Whether that’s supply chain auditing to understand how IR35 is being managed, extensive reviews of internal processes or an assessment on staff training to identify any knowledge gaps and additional learning required. 

They’ll work with you to assess the key areas they recommend tackling first, before devising a tailored plan that best fits your business’s IR35 concerns. 

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The list recognises organisations that excel in supporting employee wellbeing. Compiled by Great Place To Work®, the rankings are based on in-depth analysis of thousands of employee surveys, exploring key aspects such as work-life balance, job satisfaction, sense of fulfilment, and financial security. The evaluation also considers how consistently positive the employee experience is across all roles and departments. 

When anonymously surveyed a resounding 97% of colleagues agreed the NRL Group was a Great Place To Work®, earning the organisation the industry-recognised accolade. Survey results have since been assessed alongside other businesses, resulting in further recognition for the NRL Group for career development as well as wellbeing. 

With a strong company culture that’s grown organically around the people in the organisation, wellbeing and looking out for colleagues have always been important to the family-owned business. This year marks 10 years since directors launched a company-wide employee benefits programme that includes a Health Cash Plan to reclaim medical expenses and access to a 24/7 employee assistance help line and counselling. Whilst in recent years investment has been made to fund a free-to-access financial wellbeing service, that provides personal finance coaches to colleagues. It followed the company voluntarily signing up to become a Real Living Wage Employer, keen to ensure everyone is pay as wage that they can comfortable live on. Whilst 11 colleagues have also trained to become Mental Health First Aiders, volunteering their time to help others who need support. 

NRL Group CEO David Redmayne was pleased to secure another important accolade that helps demonstrate the company’s culture. 

“We want everyone who works in the NRL Group to feel valued, that they are not alone, and that we are always here to support them. If they are going through something at home then it’s important to us we’re able to provide assistance to help them, and we’re pleased to be able to roll out wellbeing initiatives such as our Mental Health First Aiders and personal finance coaches to do this. We’ve always committed both financially and personally to make the NRL Group an employer who cares, and recognition such as the UK’s Best Workplaces for Wellbeing™ is very much appreciated.” 

Discussing the latest listing, Benedict Gautrey, Managing Director of Great Place To Work UK said: 

“A thriving workplace culture is rooted in trust, pride, camaraderie, and a genuine commitment to employee wellbeing. As we mark the fourth year of the UK’s Best Workplaces for Wellbeing™ list, we’re proud to celebrate organisations that go above and beyond to support their people’s mental, physical, financial, and social health. When employees feel truly valued and supported, they’re not only healthier – they’re also more energised, motivated and aligned with their organisation’s goals. Congratulations to the NRL Group on earning a well-deserved place on this prestigious list.” 

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Linx and the wider NRL Group have been recognised for their commitment to learning and development, reaching position 32 on the UK’s Best Workplaces for Development™ List for medium-sized organisations.

Published by Great Place To Work®, the UK’s Best Workplaces for Development™ List is compiled following comprehensive analysis of colleague feedback captured through an anonymous survey. New for 2025, the list is designed to highlight those companies who are prioritising learning and development and making it part of their company culture. It follows the NRL Group being recognised in March in position 28 on the UK’s Best Workplaces List for medium-sized organisations.

To understand each company’s learning and development strategy, colleagues who completed the Great Place To Work^® survey were asked to rate their employer in key areas. 90% of NRL Group employees surveyed said they were offered training or development to further themselves professionally, and 91% felt they were given the appropriate information and training to do their jobs well. Crucially 92% agreed management shows a sincere interest in them as a person, not just an employee.

Analysis of survey responses paid particular focus on businesses understanding that development should not be a one-size fits all approach, which the NRL Group demonstrates through individual personal development plans for colleagues and a range of training options including formal qualifications, mentorships and 1-2-1 support.

Commenting on the launch of the new list, Benedict Gautrey, Managing Director of Great Place To Work® UK said:

“Training and development aren’t just about helping employees perform their day-to-day tasks – it’s about demonstrating that people are valued and that there’s a clear path for growth and inclusion. When employees can’t see opportunities ahead, they’re less likely to be fully engaged. Development is all about looking forward – it shows a commitment to an employee’s long-term potential. It helps individuals feel appreciated and plays a vital role in shaping a strong company culture.

Every year, we celebrate organisations that are building exceptional workplace cultures where people and businesses thrive. Learning and development opportunities are a key part of that, which is why we’re especially excited to be unveiling the UK’s Best Workplaces for Development.”

NRL Group CEO David Redmayne was delighted to be recognised on the list.

“Across our business operations we have fantastic people delivering our services, so it’s important to us that we’re able to provide them with the support they need to grow and excel in their roles. A key part of this is working with them to provide the right learning and development programmes, whilst identifying where they can take on more responsibility.

It was rewarding to see the positive feedback colleagues shared through our Great Place To Work^® survey, together with the long service awards we regularly celebrate it’s gratifying to know that our colleagues value working within the NRL Group. I’ve had the privilege of seeing colleagues develop their careers within our business across decades, myself included, and as a family-owned business every promotion is personally rewarding for us.”

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