Fractional Marketing Directors · Updated October 2026 ✓ HMRC-sourced

MTD for Fractional Marketing Directors —
Ad Spend, Performance Fees and Your Threshold

10 October 2026 ⏱ 5 min read Editorial policy ↗ HMRC eligibility guidance ↗
⚡ Check Your Marketing Income
Are your fees above the MTD threshold?
Retainers and day-rate fees (annual total)
£
Performance fees, bonuses and workshops
£
Property or other self-employment income
£
Which tax year do these figures cover?

Add every client together. Leave out client ad spend you pay on their behalf and are repaid at cost. Ask your accountant how any such pass-through is recorded.

The one-line answer
  • Your fees from every client add together. Four retainers of £1,500 a month are £72,000, well above the £50,000 line.
  • Client ad spend you pay on their behalf needs care: money passed through at cost is not your fee, but anything you mark up is part of your turnover.
  • Performance bonuses, workshops and training days add to your retainers for the threshold test.

A fractional marketing director sits between clients and a long list of third-party costs: ad accounts, agencies, freelancers, tools and events. For Making Tax Digital the question is which of those flows are your income and which are simply money passing through. This guide concentrates on that line, on performance and bonus fees, and on the records that keep a multi-client practice clean.

Are Fractional CMOs and Marketing Leads in MTD?

If you invoice as a sole trader and your gross fees (with any property or other self-employed income) are over the threshold for the relevant tax year, yes. The first line was £50,000, tested on your 2024–25 return:

Tax Year TestedGross Income OverMTD Start Date
2024–25£50,0006 April 2026. Live now
2025–26£30,0006 April 2027
2026–27£20,0006 April 2028

If your clients pay a limited company you own, the company is outside Making Tax Digital for Income Tax and dividends do not count. Fees paid to you personally, and any rental or other self-employed income, still do. See sole trader vs limited company.

Ad Spend and Third-Party Costs: Income or Pass-Through?

Marketing leads often pay for things on a client’s behalf: a Meta or Google ad budget on your card, a freelancer’s invoice, a tool licence. How that is treated depends on how it is invoiced.

SituationUsual treatment
Client pays the ad platform directlyNot your income or expense
You pay the platform and recharge the client at exact costMay be a pass-through; ask your accountant
You pay and recharge with a mark-up or management feeThe invoiced amount is turnover; your cost is an expense
A freelancer you engage and invoice on as part of your feeTurnover, with their fee as an expense
Ask before you net it off. Leaving a large recharge out of your income can understate the figure compared with the threshold. Settle the treatment with your accountant at the start of the engagement, and keep the invoice and the supplier bill together.

Performance Fees, Bonuses and Workshops

Many marketing leads earn a base retainer plus a performance element tied to leads, revenue or a campaign result. These are self-employed income and add to your retainers for the threshold, whenever they are paid. Workshops, training days and speaking fees paid gross count too.

  • Record performance fees as their own category so you can see how much of your income depends on results.
  • Keep the agreement that sets the target and the calculation of the fee.
  • Record a late-paid bonus when it is received, not when the campaign ends, if you use cash basis.

What a Fractional Marketing Director Can Claim

ExpenseNotes
Marketing softwareCRM, analytics, email, SEO and design tools you pay for
Freelancers and subcontractorsDesigners, copywriters and media buyers you engage
Conferences and eventsTickets and travel where they relate to your work
Client-site travel45p a mile for the first 10,000 miles, then 25p
Co-working and home officeDesks, meeting rooms or a flat-rate share of home costs
Insurance and membershipsProfessional indemnity, CIM or similar bodies
Training and accountancyCPD and your own tax return
UpdatePeriod (standard)Deadline2026–27
Q16 Apr – 5 Jul 20267 Aug 2026No points if late
Q26 Jul – 5 Oct 20267 Nov 2026No points if late
Q36 Oct 2026 – 5 Jan 20277 Feb 2027No points if late
Q46 Jan – 5 Apr 20277 May 2027No points if late

The soft landing means no points for late quarterly updates in 2026–27. The points system starts on 6 April 2027, with a £200 fixed penalty at four points. HMRC has also been signing up eligible customers since September 2026, so get ahead of it and register yourself. See the registration guide and the software comparison.

Worked Example

Sara Whitlock, fractional CMO for four businesses

Four monthly retainers of £1,500 over 12 months£72,000
Workshops and training days£4,800
Performance bonuses£6,200
Client ad spend paid direct by clients (not counted)£28,000
Sara’s MTD qualifying income£83,000

Sara’s clients pay their ad platforms directly, so that £28,000 never touches her accounts. Her software and freelancer costs lower her taxable profit but not the £83,000 total. She has been in MTD since April 2026.

Frequently Asked Questions

Do fractional marketing directors have to use Making Tax Digital?

If you invoice as a sole trader and your gross fees were over £50,000 in 2024–25, yes, from 6 April 2026. Over £30,000 in 2025–26 means April 2027, and over £20,000 in 2026–27 means April 2028.

Does client ad spend count as my income?

Not if the client pays the platform directly. If you pay and recharge at cost it may be a pass-through, but anything you mark up is turnover, so ask your accountant how to record it.

Do performance bonuses count?

Yes. Performance and bonus fees paid to you as a sole trader add to your retainers for the threshold test.

What about freelancers I engage for a client?

If you invoice the client for their work as part of your fee, the full invoiced amount is turnover and what you pay the freelancer is an expense.

I invoice through my own limited company. Am I in MTD?

The company is not in Making Tax Digital for Income Tax, and dividends are not qualifying income. Any separate self-employed or rental income in your own name still counts.

Do I add all my clients together?

Yes. The threshold is tested on your combined fees from every client, not retainer by retainer.

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