Financial Advisers · Mortgage Brokers · Updated September 2026 ✓ HMRC-sourced

MTD for Financial Advisers & Mortgage Brokers —
What Actually Counts as Your Income

12 September 2026 ⏱ 10 min read Editorial policy ↗ HMRC eligibility guidance ↗
⚡ Check Your Adviser Income
Are you above the MTD threshold?
Your share of commission and fees received (gross)
£
Any other self-employment income
£

Use what you actually received after your network or principal firm's split, not their gross billing, before your own business costs are deducted.

The one-line answer
  • If you're self-employed (including as an Appointed Representative under a network), the same £50k / £30k / £20k MTD thresholds apply to you as any other sole trader.
  • Your qualifying income is what you actually receive after your network or principal firm's commission split, not the gross procuration fee or client fee the network bills.
  • Many advisers and brokers operate through their own limited company instead, which sits outside MTD for Income Tax entirely, worth checking which structure you're actually in.

If you're a self-employed financial adviser or mortgage broker, working under your own name, as a sole trader, or as an Appointed Representative (AR) of a network, Making Tax Digital applies to you in exactly the same way it applies to any other self-employed person. The part that trips people up isn't the general MTD rules, it's working out what your actual qualifying income is, once network splits, procuration fees and client fees are all in the mix.

The headline issue: lenders pay procuration fees, and clients pay advice fees, to the network or principal firm your business sits under, not directly to you. The network then pays you your agreed share, commonly anywhere from 70% to 90% depending on your arrangement. It's easy to look at a lender's fee statement and assume that gross figure is "your income" for MTD purposes. it isn't. What matters is what actually lands in your business.

Are You Affected by MTD as a Financial Adviser or Broker?

Yes, if you are self-employed (including as a sole trader AR under a network) and your gross qualifying income, plus any other self-employment or rental income, exceeds the relevant threshold:

Tax Year AssessedThresholdMTD Start Date
2024–25Over £50,0006 April 2026. Live since April 2026
2025–26Over £30,0006 April 2027
2026–27Over £20,0006 April 2028

Advice and mortgage broking income is naturally lumpy. a strong quarter around a busy remortgage window, or a run of protection sales, can push your annual total well above £50,000 even if your month-to-month income feels inconsistent. It's your income across the full tax year that's assessed, not any single quarter.

Appointed Representative Splits — What Actually Counts as Your Income

Most self-employed advisers and brokers in the UK operate as an Appointed Representative of a network, rather than holding their own FCA authorisation directly. The network is FCA-authorised; you operate under its permissions, and in return the network takes a percentage of every procuration fee and client fee you generate, in exchange for compliance oversight, PI insurance cover, and back-office support.

  • Your qualifying income is your net share after the network's split, this is the figure that's actually paid into your business, and it's what determines your MTD threshold and what you report as turnover.
  • The network's statement will usually show both figures, the gross fee generated and your share after the split. Use the "your share" figure, not the headline number, when working out where you stand.
  • If your network fee or platform fee is deducted before payment, similar to how Etsy or Upwork take a cut before paying out, the same principle applies: it's what you actually received that counts, not the pre-deduction figure.
Practical tip: ask your network for an annual income summary that shows your net share by tax year, most provide this automatically for Self Assessment purposes. Feed that figure directly into your MTD software rather than reconciling every individual case statement yourself.

Commission Timing, Clawbacks and the Cash Basis

Most self-employed advisers and brokers use the cash basis, meaning income is recorded when it's actually received, not when the case completes or the policy is sold. This has a genuinely useful side effect for MTD purposes: clawbacks.

Protection and mortgage business often carries a clawback period, if a client cancels their policy or remortgages away within (commonly) the first 12 months, some or all of your commission can be reclaimed by the lender or provider. Under the cash basis, a clawback is simply recorded as a deduction in the period it happens, it reduces your income in that later period, rather than requiring you to go back and restate an earlier quarter's MTD update.

What You Can Claim as a Self-Employed Adviser or Broker

Expense CategoryExamples
Network and platform feesAny fixed platform or compliance fee charged separately from the commission split
Professional indemnity insuranceOften arranged via the network, but check whether you pay a personal top-up
Qualifications and CPDCII, CeMAP, LIBF exam and membership fees, structured CPD courses
Sourcing and CRM softwareMortgage sourcing systems, client relationship management tools not provided free by your network
MarketingWebsite, local advertising, referral partner events
Use of home / officeSimplified flat rate, or a proportion of costs if you rent a local office

Sole Trader, AR, or Limited Company — Does It Change Your MTD Position?

A meaningful number of financial advisers and mortgage brokers operate through their own limited company rather than as a sole trader, sometimes as an AR of a network where the AR agreement is held by the company, not the individual. If that's your structure, MTD for Income Tax does not apply to you personally, since it only reaches sole trader and property income, not company profits (which are taxed separately under Corporation Tax and dividends).

It's worth checking your actual arrangement with your network or compliance department if you're unsure. some advisers assume they're incorporated when they're actually trading as a sole trader AR, and vice versa.

Worked Example

Priya. Self-employed mortgage broker, AR of a network

Gross procuration fees + client fees generated£92,000
Network split (Priya keeps 80%)£73,600
Protection commission clawback (client cancelled)−£1,100
Priya's MTD qualifying income£72,500

Priya's threshold check uses her £72,500 net share, not the £92,000 the network billed lenders and clients. That's well above the £50,000 Phase 1 threshold, so MTD already applies to her.

Frequently Asked Questions

Do I use the network's gross billing or my net share for the MTD threshold?

Your net share, what you actually received after the network's commission split. The gross procuration fee or client fee billed by the network is not your income for MTD purposes, only your agreed percentage of it is.

What's the MTD threshold for self-employed financial advisers and mortgage brokers?

The same as any sole trader: over £50,000 gross qualifying income in 2024–25 means MTD from April 2026, over £30,000 in 2025–26 means April 2027, over £20,000 in 2026–27 means April 2028.

How do commission clawbacks affect my MTD figures?

If you use the cash basis (most self-employed advisers do), a clawback is simply recorded as a deduction in the period it happens. It reduces that period's income rather than requiring you to restate an earlier quarterly update.

I operate through my own limited company. Does MTD apply to me?

No, not personally. MTD for Income Tax only applies to sole trader self-employment and property income. Company profits are taxed under Corporation Tax and dividend rules, which sit outside MTD's current scope.

Does the £50,000 threshold apply to gross fees generated or my take-home profit?

Neither, precisely, it applies to your gross qualifying income, which for an AR means your net share after the network split, before your own business expenses (software, insurance, CPD) are deducted.

What software do I need as a self-employed adviser or broker?

Any HMRC-recognised MTD software works. There's no adviser-specific requirement, the main need is a clean way to record your net commission receipts and clawbacks, which standard MTD software handles without issue.

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