From the 2026 Levy Return, employers will be asked to complete two new data fields:

• On the paper Levy Return these are in section 3b and are called Box G and H

• On the online portal these questions will be in the ‘payments’ section with subheading ‘payments to labour agencies, umbrella companies or similar organisations’

Throughout this guidance they will be referred to as Box G and H.

Important points for employers:

• These figures are collected for research and insight only

• They do not affect Levy liability

• They help CITB better understand how labour is supplied across the industry.

Why CITB is collecting this information

Many employers now source labour via:

• Labour agencies

• Umbrella companies

• CIS payroll providers

• Other labour or payment intermediaries.

Collecting this data allows CITB to:

• Understand labour supply trends

• Identify how widely different labour models are used

• Inform future Levy strategy planning.

What we are asking for

"Payments to labour agencies, umbrella companies, CIS payroll providers and similar organisations."

The reason we refer to ‘similar organisations’ is these types of businesses are known by multiple terms (e.g. contracting and payment services, staffing agencies, CIS payroll service, CIS payment intermediary, CIS payroll bureau, labour/resource providers, labour/payroll solutions providers).

Many of these terms are interchangeable, but it’s the service they provide rather than what they are called, which is important.

Payments may be for temporary or longer‑term labour.

Types of suppliers to be included/excluded

Included:

• Labour agency: Supplies workers it employs for long-term or temporary roles

• Umbrella company: Acts as a payment intermediary between a subcontractor and an end client. Employing and paying workers on behalf of employment businesses

• CIS payroll provider / CIS payment intermediary: Manages CIS verification, deductions, payroll processing, and compliance for subcontractors. Reduces administrative and HMRC compliance burden for employers

• Similar organisations: Any business providing CIS intermediary services, regardless of naming conventions.

Excluded:

• Recruitment agency: Finds workers for permanent roles but does not employ the worker

Data collection

What Box G asks for:

"Total payments made through CIS to labour agencies, umbrella companies, CIS payroll providers or similar organisations with gross payment status from 6 April 2025 to 5 April 2026"

Where employers can find the payments:

• Monthly CIS 300 return submissions to HMRC

• Add together 12 months of CIS payments to relevant businesses

• Include only payments to labour agencies, umbrella companies, CIS Payroll Providers or similar organisations and only where no tax has been deducted

• There are some instances where employers incorrectly exclude payments to gross paid subcontractors on their CIS Returns (this is against CIS340 guidance). If this is the case the information should be obtained from alternative reports.

The guidance is in alignment with HMRC’s CIS regulations and assumes employers will declare payments in Box G in accordance with their CIS obligations.

Monthly CIS return example

This is how a correctly filled in example should look (insert link here to pages 6-7 of the guidance booklet).

In summary, Box G should include/exclude:

What Box H asks for:

"Total payments made outside CIS to labour agencies, umbrella companies or similar organisations from 6 April 2025 to 5 April 2026"

Where employers can find the payments:

• Purchase ledger / accounts payable

• Supplier or nominal code reports.

Box H aims to collect all labour agency payments made by an employer outside of CIS regardless of the activity being carried out.

This includes those specifically excluded under CIS. As an example, CIS specifically excludes the following activities and should therefore be included in Box H if paid via a labour agency.

• Professional services (such as architects, surveyors, and other consultants)

• Running a canteen, hostel, or other site facilities

• Site security, medical, or safety services

• Cleaning services

• Additional activities excluded for CIS purposes are set out at s74(3) of the Finance Act 2004.

In summary Box H should include/exclude:

Worked examples

Case study 1: Agency labour under CIS (Gross Payment Status)

Scenario: ABC Construction engages a labour agency operating under CIS with Gross Payment Status. In May 2025, ABC pays £30,000 for labour, £1,500 commission, and £2,000 travel/subsistence. VAT £6,700.

Action: Include £33,500 in Box G (all payments excluding VAT).

Data source: June 2025 CIS return summary showing payments to the agency.

Case study 2: Mixed contract

Scenario: GHI Build contracts a supplier to provide on‑site labour and minor consulting support on one contract/invoice. Total £25,000 (no VAT), paid under CIS Gross Payment Status.

Action: Include the full £25,000 in Box G. CIS rules treat the whole contract as within CIS where any part is within scope; separate invoices to avoid CIS are not permitted.

Case study 3: CIS payroll provider

Scenario: JKL Construction regularly uses a considerable number of CIS workers who have taxable CIS status. They have decided to reduce their admin burden by using the services of a CIS Payroll Provider who pays the same workers on their behalf. Total is £50,000 per month every month for a year (excluding VAT), paid under CIS Gross Payment Status.

Action: Include £600,000 in Box G (£50,000 x 12 months)

Case study 4: Labour agency

Scenario: MNO Builders decide to engage an agency to find a person to clean their offices. The person found is employed and paid by the agency and MNO Builders pay the agency. Total is £650 per month (excluding VAT). The cleaner started on 1st September.

Action: Include £4,550 (excluding VAT) in Box H (£650 x 7 months)