IR35: HMRC “Updates” CEST – But Nothing’s Really Changed

IR35: HMRC “Updates” CEST – But Nothing’s Really Changed
Article by: EEBS Team

HMRC’s first update to the Check Employment Status for Tax (CEST) tool in over four years promised clarity, but has changed very little. The questions remain the same, the logic is unchanged, and the only differences are minor wording and layout tweaks.

What has changed is the supporting guidance. If you’re using CEST, you’re now expected to consult HMRC’s employment status manual to understand how the tool works in practice. Key decisions about substitution, control, and financial risk aren’t built into the tool itself – they’re buried in the guidance.

In short, the tool is still based on outdated case law from 2019. It doesn’t reflect major rulings since then, and it’s becoming increasingly disconnected from the reality of modern contracting.

If you rely on CEST alone, you may be exposing your business to unnecessary risk.

At EEBS, we understand how things work in the real world. That’s why we’ll be keeping both clients and subcontractors informed, delivering regular briefings over the coming year to help you stay ahead of any changes. We’re also actively developing solutions to meet the new requirements head-on.

Our advice? Don’t rely on CEST alone. If you want to stay compliant and protected, speak to EEBS who understand the risks, and how to manage them.

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