MTD for Locum GPs & Doctors —
Session Fees, PAYE Shifts and Your Threshold
Use gross fees before indemnity, GMC fees and travel. Leave out anything paid through a payslip, and your NHS salary or pension.
- Only self-employed income counts: session fees you invoice, private clinics and medico-legal reports. PAYE-paid shifts, a salaried NHS post and NHS pension income do not.
- The test uses gross fees before indemnity, GMC fees and travel, so a full-time locum GP is very likely above the £50,000 line already.
- HMRC looks at each engagement on its own facts, so one doctor can have PAYE shifts and self-employed sessions side by side in the same year.
If you locum as a GP or hospital doctor and invoice practices, out-of-hours providers or private clinics yourself, HMRC treats you as a sole trader, and on typical session rates you are very likely above the £50,000 line that brought the first wave into Making Tax Digital in April 2026. This guide covers which of your income counts, how a mix of PAYE and self-employed work is handled, and what your digital records need to show.
Are Locum GPs and Doctors in MTD?
Yes, if your gross self-employed income (together with any property income) is over the threshold for the relevant tax year. HMRC checks the figures on your Self Assessment return, so the £50,000 test used your 2024–25 return:
| Tax Year Tested | Gross Income Over | MTD Start Date |
|---|---|---|
| 2024–25 | £50,000 | 6 April 2026. Live now |
| 2025–26 | £30,000 | 6 April 2027 |
| 2026–27 | £20,000 | 6 April 2028 |
The figure is your gross fees before any expenses. Indemnity, GMC registration and travel are deducted later when your profit is worked out, not when the threshold is checked. A locum doing four or five sessions a week at a typical day rate can pass £50,000 in the first half of a year, which is why this group was among the first to be pulled in.
Which Doctor Income Counts (and What Doesn’t)
| Income | Counts towards the threshold? |
|---|---|
| Locum session fees you invoice to a practice or primary care network | Yes |
| Out-of-hours or urgent care sessions you invoice yourself | Yes |
| Private consultations or clinic sessions | Yes |
| Medico-legal and expert witness reports | Yes |
| Examiner, appraiser or teaching fees paid with no tax deducted | Usually yes, check the status |
| Hospital bank or agency shifts paid through a payslip | No (employment income) |
| A salaried NHS or practice post | No |
| NHS pension, interest, dividends from your own company | No |
| Rental income from property you let out | Yes, added to the total |
Income is added up across every self-employed source. A locum with £38,000 of session fees and £14,000 of rental income has £52,000 of qualifying income, even though neither number alone crosses the line.
Employed or Self-Employed? Each Engagement Is Judged Separately
The practical test is simple. If tax and National Insurance come off before you are paid and you receive a payslip, that income is employment income and stays out of MTD. If you invoice, are paid in full and settle your own tax, it is self-employed income and is counted. Work through an umbrella company is employment income too.
If you trade through your own limited company, the company is not in Making Tax Digital for Income Tax. Dividends you draw are not qualifying income, although you may have other self-employed or property income that is. See sole trader vs limited company for the comparison.
What Locum Doctors Can Claim
| Expense | Notes |
|---|---|
| Medical indemnity | Annual subscription for your locum work, from your defence organisation |
| GMC registration | Annual retention fee, plus licence to practise costs |
| Professional bodies | RCGP, BMA or royal college membership relevant to your work |
| Appraisal and revalidation | Fees and costs tied to keeping your registration |
| CPD and courses | Training that maintains the skills you already use |
| Travel between sites | 45p a mile for the first 10,000 miles, then 25p, plus parking |
| Equipment and reference tools | Diagnostic kit, bag, clinical reference subscriptions |
| Admin and accountancy | Phone, software, accountancy fees, a proportion of home office costs |
Travel needs care. A practice you attend for a short, temporary period is normally an allowable destination. If you end up working at the same practice for long stretches, it can start to look like a regular workplace, so check with your accountant before claiming the mileage.
If a practice deducts pension contributions from your fee at source, record the full invoiced fee as income and ask your accountant how the contribution should be treated. Pension relief does not change the MTD threshold figure.
Keeping Digital Records Across Several Practices
Sessions, invoices and payments rarely line up in the same quarter, so a simple per-session log does most of the work. For every session record the date, the practice, the hours or sessions worked, the rate, your invoice number and the date it was paid. Most locums use accounting software that matches bank payments to invoices.
- Keep income from different practices in one self-employment record. You do not need a separate record per practice.
- Keep any PAYE payslip shifts out of the self-employed record, so the quarterly figures are clean.
- Record private and medico-legal income as its own category so it is easy to spot at year end.
- Upload receipts for indemnity, GMC and courses as you pay them, not in one sitting in January.
You then send four short quarterly updates a year from your software, plus a final declaration by 31 January. The updates are summaries, not tax returns, and a well-kept session log makes each one a matter of minutes.
| Update | Period (standard) | Deadline | 2026–27 |
|---|---|---|---|
| Q1 | 6 Apr – 5 Jul 2026 | 7 Aug 2026 | No points if late |
| Q2 | 6 Jul – 5 Oct 2026 | 7 Nov 2026 | No points if late |
| Q3 | 6 Oct 2026 – 5 Jan 2027 | 7 Feb 2027 | No points if late |
| Q4 | 6 Jan – 5 Apr 2027 | 7 May 2027 | No points if late |
No penalty points apply to late quarterly updates this tax year. From 6 April 2027 a point is added for every update missed, and reaching four triggers a £200 fixed penalty. HMRC started signing up eligible customers in September 2026, so do not wait for a letter. See the software comparison and the registration guide.
Common Mistakes Locum Doctors Make
- Counting PAYE shifts. Bank and agency shifts paid through a payslip are employment income and do not count towards the threshold.
- Testing against take-home pay. The line is crossed on gross fees, not on what is left after indemnity, tax and pension.
- Forgetting private work. Medico-legal reports, cremation forms and private clinics all add up and all count.
- Assuming a company protects you. A limited company is outside MTD, but any self-employed or rental income you also have is not.
- Waiting for a letter. If your 2024–25 return showed more than £50,000, you should already be signed up.
Worked Example
Dr Priya Nair, locum GP covering seven practices
Priya’s hospital payslip shifts are employment income and are left out. Her £98,100 of invoiced work is well over £50,000, so she has been in MTD since April 2026. Her £6,900 of indemnity and GMC costs reduce her profit, not her threshold figure.
Frequently Asked Questions
Do locum GPs have to use Making Tax Digital?
If your gross self-employed income was over £50,000 in 2024–25, yes, from 6 April 2026. If it was over £30,000 in 2025–26 you join in April 2027, and over £20,000 in 2026–27 means April 2028.
Does my salaried NHS job count towards the threshold?
No. Only self-employment and property income count. Salary paid through payroll, NHS pension income, interest and dividends are all left out of the figure.
What if I only locum through my own limited company?
The company itself is not in Making Tax Digital for Income Tax, and dividends are not qualifying income. Any separate self-employed or rental income you have in your own name still counts.
Do I count my fees before or after the practice deducts pension contributions?
Count the full fee you invoiced. Deductions made at source are handled separately for tax purposes, so ask your accountant how to record them. They do not reduce the threshold figure.
Can I claim medical indemnity and GMC fees?
Yes, both are normal business expenses against your self-employed locum income. They reduce your taxable profit but are not subtracted when HMRC tests your income against the threshold.
How do I handle a practice that pays me months late?
Record the income according to your accounting basis, which is usually when the money is received. Keep the invoice date in your log so you can show the work was done and chase the practice if needed.
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