Last reviewed: 15 June 2026
Quick summary
- MTD can apply to self-employed CIS subcontractors based on qualifying income thresholds.
- CIS tax deductions are not the same as expenses; keep gross invoices and deduction statements separately.
- The best MTD setup for subcontractors tracks labour, materials, contractor statements, mileage, tools and CIS tax suffered.
Topic hub: Making Tax Digital by business type
Direct answer
Self-employed CIS subcontractors may need Making Tax Digital for Income Tax if their qualifying self-employment and property income is above the current GOV.UK thresholds. CIS deductions do not mean MTD is irrelevant. They are tax withheld by contractors, while MTD is about digital records and quarterly updates for qualifying income and expenses.
The key record issue is gross versus net. If a contractor pays you after deducting CIS tax, your bank deposit is not the full story. You need the gross amount, CIS deduction, materials where relevant, contractor name, payment date and expense records.
The CIS subcontractor money model
A subcontractor may invoice a contractor for labour, materials and sometimes plant, travel or extras. The contractor may verify the subcontractor and deduct CIS at the relevant rate. The bank may only show the net payment after deduction, but the tax return and MTD records need to recognise the underlying income and the tax already deducted.
This is why MTD for CIS is not just "connect the bank account". A bank feed can show net receipts, but it may not show the deduction statement. It also may not split labour from materials, or show whether a payment relates to a particular month, job, retention or correction. Good digital records should match invoices to contractor deduction statements and bank deposits.
Competitor pages often sell construction software or make broad statements about quarterly updates. Accountancy Ally should beat them by giving the subcontractor a practical pack: gross invoices, CIS statements, materials evidence, tools, mileage, insurance and a list of questions to ask before paying for software.
Examples where CIS subcontractors get stuck
- A carpenter receives £2,400 in the bank after CIS has been deducted. The accountant needs the gross invoice and deduction statement, not only the deposit.
- A builder charges for materials and labour on the same invoice. The material element should be evidenced separately because it affects CIS treatment and profit records.
- A subcontractor works for three contractors and one sends late deduction statements. The record process should chase missing statements monthly, not at tax-return time.
- A tradesperson has CIS work and separate domestic jobs outside CIS. Both income streams may be self-employment income, but the records and tax deductions differ.
- A subcontractor uses a personal van for work. Mileage, fuel, repairs, finance and private-use notes should be decided consistently.
Records to gather before asking for help
- Invoices showing gross labour, materials and VAT if applicable.
- Monthly CIS deduction statements from each contractor.
- Bank deposits matched to invoices and statements.
- Materials receipts and supplier statements.
- Tools, PPE, workwear, insurance, training and professional costs.
- Van, mileage, fuel, repairs, parking, tolls and finance records.
- Retentions, corrections, disputed invoices and unpaid invoices.
- Your latest Self Assessment return and any HMRC MTD letter.
Common mistakes
The biggest mistake is treating net CIS bank receipts as turnover. That can understate income and make the MTD threshold check unreliable. A second mistake is treating CIS deductions like ordinary business expenses. They are tax already deducted, so they need to be tracked separately from materials, tools or mileage.
A third mistake is assuming that being "under CIS" means the contractor has handled your tax completely. CIS can reduce the final tax bill or create a refund, but you may still need Self Assessment, proper expense records and MTD if thresholds are met. Subcontractors should also avoid choosing software that cannot handle deduction statements cleanly.
What to write in your first accountant message
Try: "I am a self-employed CIS subcontractor. My gross CIS invoices last tax year were about this amount before CIS deductions. I also have these non-CIS jobs. I need to know when MTD applies and how to record gross income, CIS deductions, materials, van costs and tools." Attach one invoice, one contractor deduction statement and a monthly income summary.
A monthly CIS workflow
For CIS subcontractors, monthly is usually the natural rhythm because contractors issue deduction statements by tax month. Save each contractor statement as soon as it arrives, then match it to your invoice and bank receipt. If a statement is missing, chase it that month. Waiting until January can turn a simple tax-credit record into a reconstruction exercise across several contractors.
Your monthly MTD pack should show gross labour, materials charged to the contractor, CIS tax deducted, net payment received, unpaid invoices, retentions and any corrections. Add expenses at the same time: materials bought yourself, tools, PPE, insurance, training, mobile phone, van costs, mileage, parking and finance costs. If you did domestic work outside CIS, keep it in a separate income line so the accountant can see the difference between CIS work and ordinary trading income.
Software and contractor-statement setup
Ask whether the software can record CIS deductions clearly or whether the accountant needs a separate CIS schedule. Some software is built for normal sales invoices but does not make contractor deduction statements obvious. If you use spreadsheets, ask what columns the accountant wants before MTD starts: contractor, invoice date, gross labour, materials, CIS deduction, VAT if relevant, net paid, bank date and statement received. That structure is often more useful than a pile of PDFs.
Questions to ask an accountant
- Should I check MTD using gross CIS income or net bank receipts?
- How should CIS deductions be recorded in the software?
- Can the software handle labour, materials, retentions and contractor statements?
- Do my non-CIS jobs need separate tracking?
- Will you handle quarterly updates and year-end CIS reconciliation?
Related guides
Key takeaway
CIS subcontractors should prepare for MTD by keeping gross invoices, CIS deductions and expenses separate. The net amount in the bank is not enough for a reliable MTD or Self Assessment record.
Official guidance checked on 15 June 2026
FAQs
Does CIS mean I have already paid all my tax?
Not necessarily. CIS deductions are tax withheld, but your final Self Assessment position depends on income, expenses and other facts.
Can I use bank deposits for MTD?
Bank deposits help, but CIS subcontractors usually need gross invoices and deduction statements too.
Does PAYE work count for MTD?
PAYE wages do not count towards MTD qualifying income, but self-employed CIS and other trading income can.