UK Accountancy Practices · Making Tax Digital

The next Making Tax Digital for Income Tax deadline is Saturday 7 November 2026. This article sets out a repeatable quarterly workflow, checked against HMRC's published guidance, and shows where a documented offshore team in India can carry production work while your practice keeps review and submission. The staffing background is covered in our earlier piece on the UK accountancy staffing crisis. In ICAEW's 2026 mid-tier research, 46% of the 35 responding firms still ranked recruiting qualified staff among their three biggest talent challenges. That is a sector-wide pressure, not a prediction for any one firm.

TL;DR
  • A quarterly update is a cumulative summary of category totals for self-employment and property income. It is not a tax return, and it must be sent before the tax return can be submitted.
  • The 2026-27 cycle dates are 7 August, 7 November, 7 February and 7 May. HMRC applies no penalty points for late quarterly updates in 2026-27. Points start for tax years after that.
  • Three gates make the cycle run: authorisation and sign-up, clean digital records, and a named reviewer with protected time.
  • A practical split is preparation by a trained team (in-house or offshore) and review and submission by your practice, under your agent services account.

1. What a quarterly update is, and what it is not

HMRC's guidance describes quarterly updates as summaries, not tax returns. Each one includes totals for every income and expense category the client has used. HMRC does not receive individual records such as a receipt or invoice. Updates cover self-employment and property income only; other income does not go into them.

Two features shape the workflow. First, every update is cumulative. It covers the period from the start of the tax year to the end of the update period, not only the last three months. Second, quarterly updates must be sent before the tax return can be submitted. After the fourth update, check whether adjustments are needed before the return is completed.

The return is submitted in the software by 31 January following the tax year, after all other income and gains are added. For a client, only a main agent can submit it, after sharing the information with the client and obtaining written confirmation that it is correct and complete.

2. Update periods, deadlines and penalties

The deadlines are the same for standard and calendar periods.

UpdateStandard periodCalendar periodDeadline (2026-27 cycle)Day
16 Apr to 5 Jul1 Apr to 30 Jun7 August 2026Friday
26 Apr to 5 Oct1 Apr to 30 Sep7 November 2026Saturday
36 Apr to 5 Jan1 Apr to 31 Dec7 February 2027Sunday
46 Apr to 5 Apr1 Apr to 31 Mar7 May 2027Friday

HMRC's guidance states that there are no penalties for missing a quarterly update deadline for the 2026 to 2027 tax year. For quarterly updates in later tax years, each missed quarterly update or tax return deadline earns one penalty point, one point per deadline however many businesses the client has. The threshold is four points, which triggers a GBP 200 penalty, and each further missed deadline adds another GBP 200. Late tax returns for 2026-27 can still attract points. Two of the four 2026-27 deadlines fall on a weekend (7 November and 7 February), and a practice that rehearses the cycle this year carries a tested process into the penalty year.

3. Gate 1: authorisation and sign-up

HMRC's agent guidance sets these steps:

  1. Hold an agent services account. It is separate from the older HMRC online services for agents account.
  2. Get the client's permission. If the client already authorised you for Self Assessment, check that the authorisation appears in your agent services account and add it if not. Adding it does not sign the client up. If you hold a digital handshake authorisation for MTD for Income Tax, you can sign the client up without adding anything manually.
  3. Check eligibility. The client must be registered for Self Assessment, must have submitted a tax return in the last two years, and must not be exempt.
  4. Sign the client up through the online agent service using full name, date of birth, National Insurance number and, for each income source, the details HMRC asks for, including the tax year the client will start using the service.
  5. Confirm the client's software works with MTD for Income Tax. The prior-year Self Assessment return must be submitted before the client starts.
Agent roleQuarterly updatesTax returnNote
Main agentCan complete and submitCan submit, including supporting documentsOne main agent per client at a time
Supporting agentCan complete and submitCannot submitAny number per client; limited access to income details

HMRC reported on 12 August 2026 that over 570,000 customers had signed up and said it would begin signing up customers who should already be using the service from September 2026, in stages. Confirm, client by client, whether HMRC has already signed someone up and who is recorded as their agent.

4. Gate 2: digital records and links

HMRC's record-keeping guidance requires digital records of self-employment and property income and expenses, each with the amount, date and category. The points that decide whether a workflow holds are these.

  • Spreadsheets are allowed, but they must be digitally linked to the bridging software that submits to HMRC.
  • No manual copying after submission. Once a record has been sent to HMRC it must not be manually moved by copying and pasting into other software or cells.
  • Timing. Records should be created as close to the date of the transaction as possible. For a quarterly update, the records for the period must exist before the deadline or the date you send the update, whichever is earlier.

In practice, reconciliation and categorisation cannot be left to a catch-up in the final week. Where clients use spreadsheets, document the linking route per client before the cycle opens.

5. The quarterly cycle, step by step

The template below assumes a 15-working-day window ahead of the internal submission date.

StepTimingTaskOwner
1. Period lockDay 1 after period endConfirm bank feeds are live, list clients with missing statements or receipts, send record requestsPreparer
2. ReconcileDays 1 to 7Bank and card reconciliations; categorise to agreed rules; log unclear items as queriesPreparer (in-house or offshore)
3. Cumulative figuresDays 5 to 9Prepare year-to-date category totals; compare with the prior update and prior year; write a two-line variance note per clientPreparer
4. Client queriesDays 5 to 10Practice contact sends consolidated queries; chase once, then escalate to the partnerPractice
5. ReviewDays 9 to 12Reviewer checks variance notes, reviews flagged items, records review points by typeReviewer
6. Client sightDay 12Figures sent to client before submissionPractice
7. SubmitDay 13 to 14Submit under your agent services account; save the HMRC receipt to the filePractice
8. BufferDay 15Late items and rejected submissionsPractice

6. Worked example: the 7 November 2026 cycle

Facts (illustrative). A UK practice has 60 clients in scope, all on standard periods, using cloud accounting software with bank feeds. The practice estimates 1.0 hour of preparation and 0.5 hour of review and submission per client per cycle. It sets an internal submission date of Thursday 5 November 2026, with Friday 6 November as the buffer, because 7 November is a Saturday.

WindowActivityHours
Thu 15 to Fri 16 OctBank-feed check, record requests, client list confirmed against agent services account6
Mon 19 to Fri 23 OctReconciliation and categorisation for 60 clients40
Mon 26 to Fri 30 OctCumulative figures, variance notes, consolidated client queries and one chase28
Mon 2 to Wed 4 NovReview of 60 files and client sight of figures22
Thu 5 NovSubmission and receipts saved8
Fri 6 NovBuffer for rejections and late items4

Reading the result. Preparation is 60 hours (60 x 1.0) and review plus submission is 30 hours (60 x 0.5), before queries and buffer. If preparation moves to a trained offshore team, the practice's own time falls to review, client contact and submission, which is where its senior time matters most. The hours are assumptions, not a benchmark. Measure review points per file and reviewer minutes per client, then adjust for 7 February 2027.

7. Where an offshore team fits

An offshore team in India adds production capacity at steps 1 to 3 of the cycle. The time difference means a reviewer can find prepared files in the morning, but the model works only if review capacity exists.

TaskOffshore teamYour practice
Bank and card reconciliationsPrepare to checklistReview exceptions
Categorisation and bank rulesApply agreed rules, raise queriesApprove any rule change
Cumulative category totals and variance notePrepareReview
Client contact and adviceNot suitableAlways
Submission to HMRC and tax returnNot suitableAlways, under your agent services account

Before client data moves, UK GDPR treats the transfer to India as a restricted transfer, so the practice needs a documented route: check adequacy, otherwise use an Article 46 safeguard such as the IDTA or the UK Addendum, and record a transfer risk assessment. Our guide to UK GDPR, Article 28 and the IDTA sets out the steps. A well-run engagement should also cover named-user access with multi-factor authentication, subcontractor limits, breach-notice timing and exit terms. The staffing playbook is in building an offshore bench.

8. Per-client sign-off checklist

A reviewer should be able to tick each line before a quarterly update is submitted.

  • Client is signed up, and your firm is recorded as main agent (or supporting agent where intended).
  • Bank and card accounts are reconciled to the period end, with no unexplained items.
  • Cumulative figures agree with the prior update plus the movement in the period, and the variance note explains changes.
  • Digital links are intact; nothing has been manually re-keyed after a record was sent.
  • Client has seen the figures and open queries are resolved or noted.
  • Submission receipt is saved to the file, with date and person.

9. Frequently asked questions

What does a quarterly update send to HMRC?

HMRC's guidance says a quarterly update includes totals for each income and expense category used, and that HMRC does not receive individual records such as a receipt or invoice. Each update is cumulative: it covers the period from the start of the tax year to the end of the update period, not just the previous three months. Updates cover self-employment and property income only.

When is the next quarterly update due?

The second update of 2026-27 is due on 7 November 2026. It covers 6 April to 5 October for standard periods, or 1 April to 30 September for calendar periods. The date falls on a Saturday, so most practices will set an internal submission date of Friday 6 November or earlier.

Are there penalties for a late quarterly update in 2026-27?

No. HMRC states there are no penalties for missing a quarterly update deadline for the 2026 to 2027 tax year. For later years, each missed quarterly update or tax return deadline earns one penalty point, and reaching the threshold of four points triggers a GBP 200 penalty. Late tax returns for 2026-27 can still attract points.

What must an agent have in place before signing a client up?

The agent needs an agent services account and the client's authorisation, through an existing Self Assessment authorisation added to the account or a digital handshake request. Adding it does not sign the client up, so each client is signed up separately.

What is the difference between a main agent and a supporting agent?

A main agent can fully manage a client's MTD for Income Tax, including submitting the tax return. A supporting agent has limited access and can see and submit quarterly income and expense updates but cannot submit the tax return. A client can have only one main agent at a time but any number of supporting agents.

Can records be kept in a spreadsheet?

Yes, if the spreadsheet is digitally linked to bridging software that makes the submission. HMRC's guidance says records should be created as close to the transaction date as possible, and that once a record has been sent to HMRC it must not be manually moved by copying and pasting into other software or cells.

Which parts of the quarterly workflow can an offshore team handle?

A well-run offshore team can handle bank and card reconciliations, categorisation to the agreed rules, preparation of cumulative category totals and a short variance note, working to a written checklist inside your software. Client communication, review, advice, and submission to HMRC stay with your practice under its own agent authorisation.

Will an offshore team certainly meet every quarterly deadline?

No. Results depend on the quality of client records, reviewer time, software set-up and the written procedures. The workflow in this article is a way to organise the work. It does not predict the position of any individual practice.

10. Sources

  • GOV.UK, Use Making Tax Digital for Income Tax: Send quarterly updates (periods, deadlines, cumulative updates, no penalties in 2026-27): gov.uk
  • GOV.UK, Penalties for Making Tax Digital for Income Tax (penalty points, GBP 200 threshold): gov.uk
  • GOV.UK, Use Making Tax Digital for Income Tax: Submit your tax return (31 January, main agent steps, client confirmation): gov.uk
  • GOV.UK, Use Making Tax Digital for Income Tax: Keep digital records (records, digital links, timing): gov.uk
  • GOV.UK, Sign up your client for Making Tax Digital for Income Tax (agent services account, eligibility, sign-up): gov.uk
  • GOV.UK, Add your client authorisations for Making Tax Digital for Income Tax: gov.uk
  • GOV.UK, Choose agents for Making Tax Digital for Income Tax (main and supporting agents): gov.uk
  • HMRC, "436,000 sole traders and landlords make their tax digital", 12 August 2026: gov.uk
  • ICAEW, Evolution of Mid-Tier Accountancy Firms 2026 (fieldwork 23 Feb to 15 Mar 2026; 35 responding firms; recruiting qualified staff one of three biggest challenges for 46%, 67% in 2024): icaew.com
Planning the 7 November cycle, or building the quarterly workflow for next year?

Somesh Chandak & Associates, Chartered Accountants (FRN 158694W), Thane, supports accounting practices abroad with bookkeeping, reconciliations and month-end close on Xero and QuickBooks Online, working under your review and your brand. We can walk through scope, workflow and the documents your practice will need before any client data moves.

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This article is for general information for accounting professionals and is not legal, tax or data-protection advice. Dates, thresholds and penalty rules are taken from HMRC's published guidance as at 15 October 2026 and may change. Confirm your own position, including the UK GDPR transfer route, with your advisers before sharing client data with any third party.