New guidance warns against ‘nil’ MTD submissions
PCRT bodies clarify standards ahead of 2026 mandate, urging tax professionals to uphold accuracy in quarterly updates.
New guidance from the UK’s leading tax and accounting professional bodies has been published to help advisers prepare for the rollout of Making Tax Digital for Income Tax (MTD for IT) from April 2026, with a focus on how Professional Conduct in Relation to Taxation (PCRT) applies in practice.
The interim guidance, issued jointly by AAT, ACCA, ATT, CIOT, ICAS, ICAEW and STEP, outlines expectations for members providing services that support digital record keeping, quarterly updates, and year-end submissions under MTD for IT.
A working group from the PCRT bodies drafted the document to address frequent questions raised by agents, particularly around accuracy, use of estimates, and the handling of third-party data.
“There has been some suggestion of submitting four quarters of nil figures in quarterly submissions (even though there were income and expenses in those quarters) and including all entries in the year-end tax return. The guidance states this would not be the correct way to approach MTD for IT under PCRT principles.”
Quarterly updates must be factually correct, the guidance stresses — and not based on assumptions, estimates, or prior data unless supported by HMRC easements. Submitting nil returns or placeholders in anticipation of updating figures later does not align with PCRT standards.
Ten FAQs published to address common agent concerns
The new guidance is structured around ten key questions, including:
- What level of accuracy is expected in quarterly submissions?
- Should errors discovered post-submission be corrected in later updates?
- What if data is provided by a third-party bookkeeper?
- How should firms manage client transitions between agents?
While not all quarterly submissions require the same level of review as a final tax return, members must still apply appropriate checks and professional judgement when submitting MTD updates on behalf of clients.
The document also clarifies that PCRT applies to any member involved in delivering MTD-related services, regardless of whether they are tax-qualified. This includes employees assisting with submissions or managing digital tools.
Further updates to the guidance are expected as mandation draws nearer and HMRC clarifies final operational details.
