Last reviewed: 11 August 2026
Quick summary
- Record every session with the practice, agency, dates, fee terms, payment route and pension-status question. An agency payment statement does not explain all of those facts.
- PCSE and NHSBSA guidance sets time-sensitive rules for relevant Locum A/B pension processes. Check the actual engagement route promptly rather than after the tax year ends.
- Keep agency, individual freelance, salaried and limited-company documents in separate lanes. They can be connected commercially but should not be merged for records or pension assumptions.
Part of GP and dentist accounting guides.
Direct answer
For a GP locum booked through an agency, make a session record that shows where the work was performed, who contracted with you, who paid you, what the agency deducted, and whether there is a pension action to consider. Save the agency booking confirmation and remittance alongside the practice name, session date and invoice or timesheet. The payment route is evidence; it is not on its own an answer to tax status, NHS pension eligibility or whether a company should be used.
PCSE says relevant Locum A/B action has a deadline measured from the end of the work, not from when you finally organise your accounts. Its current guidance also addresses locum work paid through an agency and into a limited company. That is why a session-by-session control is safer than trying to rebuild a year of locum work from bank receipts after the deadline has passed.
The three-party record: practice, agency and you
Agencies create a natural information gap. The agency may hold the booking, negotiate a rate, invoice a practice and pay a remittance after a commission or other deduction. The practice is where the clinical session occurred. You are the person whose tax and pension records need to make sense. Put all three names in the same record.
- Practice lane: date, site, session type, clinician rota or timesheet, named contact and work actually performed.
- Agency lane: booking confirmation, assignment terms, agency commission, agreed rate, remittance, any cancellation or adjustment and its payment reference.
- Your lane: invoice or payment request, bank receipt, expenses, pension decision/form status and whether the engagement is personal, salaried or company activity.
If a payment covers several sessions, make the remittance total agree back to individual session rows. A useful column is 'unexplained difference': it forces you to identify a fee, cancellation, payroll deduction, late payment or missing session before it becomes invisible.
Pension records need their own deadline control
Do not use an agency remittance as a substitute for Locum A/B documentation. PCSE's current locum guidance says the relevant form route is time sensitive, and NHSBSA states that a period of freelance GP locum work ending more than 10 weeks ago cannot be pensioned under that route. Whether a session is pensionable is a fact-specific scheme question, so this page does not label an agency booking either way.
Instead, add five fields to each session: work end date, pension route checked, Locum A status, Locum B status and evidence sent/received. If the work is via a limited company, flag it immediately. The current NHSBSA/PCSE material includes specific treatment for income paid to a company. A medical accountant can help you separate the pension decision from the broader company and tax records, but they need the engagement facts early.
Three common agency-payment patterns
- Direct individual locum, agency arranges booking: keep the practice session evidence and agency paperwork together. Confirm the pension route before assuming the remittance describes it.
- Agency pays a monthly batch: match each remittance line to the individual clinical dates, rates and commission. Record payment delays separately from the date the work ended.
- Agency payment into a company: retain the contract party, company invoice, company bank receipt and any pension correspondence. Do not copy a personal freelance-locum pension workflow into the company records without checking current guidance.
These examples are deliberately about evidence, not a universal recommendation about working through a company. Entity choice, status and pension membership are separate professional questions.
Records to take to a medical accountant
- Agency terms, booking confirmations, rate cards, timesheets and remittance statements.
- Practice names, dates, locations, session type and evidence of work performed.
- Invoices, payment requests, bank receipts and a reconciliation of commission/deductions.
- Locum A/B forms, confirmations, contributions, deadlines and correspondence with PCSE/NHSBSA.
- P60s and payslips for salaried work, plus separate company records where applicable.
- Professional indemnity, chambers/agency costs, travel and other expense evidence with a business-purpose note.
Common mistakes
Do not call an agency commission a missing payment. Do not use an invoice date as evidence of when a clinical session ended. Do not assume an agency's description of an engagement settles employment status. Do not include salaried pay, individual freelance receipts and company receipts in a single spreadsheet column called 'locum income'.
Another common issue is submitting pension paperwork only after a tax-return review. The forms are operational records with their own timetable. A short review after each month is more valuable than an annual reconstruction, especially where a practice has not completed an expected step or an agency remittance does not agree with the sessions you logged.
Questions for an accountant
- For each recent agency assignment, what documents establish the personal, agency, practice and company routes?
- Which sessions need urgent pension-route confirmation or form follow-up?
- How should I reconcile agency commission, expenses and late remittances without losing gross fee evidence?
- How should salaried work, freelance locum work and company payments be kept separate for tax and pension preparation?
- What should I do when an agency statement, practice timesheet and bank payment do not agree?
Related guides
Key takeaway
The agency is a payment route, not the whole accounting story. Make each clinical session traceable from practice to agency to bank, then capture the pension question and deadline while the details are still current.
Sources checked on 11 August 2026
Frequently asked questions
Does an agency remittance replace GP locum pension records?
No. Retain the practice session, agency paperwork, payment record and pension documentation as separate but connected evidence.
Can income paid to a limited company be pensioned as freelance GP locum income?
PCSE and NHSBSA have specific rules. Check the current guidance for the engagement route promptly and seek medical-accountant support where needed.