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Home / Tax Guides / CIS / CIS vs PAYE
Construction Industry Scheme Guide

CIS vs PAYE: Subcontractor or Employee?

Understand the difference between being genuinely self-employed under CIS and working as an employee through PAYE, why registration does not decide employment status and what HMRC considers.

Updated: 18 August 2026 Employment Status CIS & PAYE
Key rule

CIS registration does not prove self-employment

The actual terms and working arrangements of each engagement determine the tax status.

CIS

Applies to qualifying construction contracts involving self-employed subcontractors.

PAYE

Applies where the construction worker is an employee.

Check each engagement

Past CIS work does not decide the status of a new contract.

On this page Main difference What is CIS? What is PAYE? Employment status Factors HMRC considers CIS registration Tax differences Expenses CEST Wrong status FAQs

What is the difference between CIS and PAYE?

CIS is a tax deduction system used for qualifying payments from construction contractors to subcontractors. PAYE is the system used by employers to deduct tax and National Insurance from employees.

Most important point

A construction worker cannot simply choose CIS instead of PAYE. The worker must actually be self-employed under the terms and circumstances of the particular engagement.

What does working under CIS mean?

CIS applies where a qualifying construction contract exists between a contractor and a subcontractor and that contract is not a contract of employment.

A registered subcontractor paid under deduction will normally have CIS deducted at the applicable rate and remains responsible for their business tax affairs.

What does working under PAYE mean?

Where the worker is an employee, the employer operates PAYE on employment income and applies the employment tax and National Insurance rules.

How is employment status decided?

HMRC says the terms of the particular engagement matter. Being registered for CIS, owning tools or having previously worked as self-employed does not by itself determine the answer.

Which factors can affect status?

Control

Who decides what work is done and how, when and where it is carried out?

Personal service

Is the worker required personally, or is there a genuine right to provide a substitute?

Financial risk

Does the worker genuinely bear business risk and responsibility for correcting defective work?

Business organisation

Is the worker genuinely operating an independent business rather than being integrated as staff?

HMRC warning

Being on the CIS register is not an employment-status test

A contractor must still consider whether the worker is genuinely self-employed when they are engaged.

Can someone registered for CIS still be an employee?

Yes.

If the facts of a particular contract create employment, PAYE applies to that engagement despite the worker's CIS registration.

How are the tax systems different?

CIS subcontractorPAYE employee
Operates a self-employed businessWorks under a contract of employment
CIS may be deducted from contractor paymentsEmployer deducts PAYE tax and relevant NIC
Reports business profit through Self AssessmentEmployment income is normally reported through payroll
Claims allowable self-employed business costsEmployment expense rules are more restrictive
Bears genuine business responsibilitiesWorks as part of the employer's workforce

Are expenses different under CIS and PAYE?

Yes. A genuinely self-employed subcontractor follows the self-employed business expense rules. Employees instead follow the employment-expense rules.

Do not mix the two systems

For example, the PAYE temporary-workplace rules should not automatically be applied to a genuinely self-employed CIS subcontractor.

Can HMRC's CEST tool help?

HMRC provides its Check Employment Status for Tax tool to give HMRC's view based on the information entered about the engagement.

HMRC says it will stand by a CEST result where the information supplied is accurate and remains consistent with its guidance.

What happens if CIS was used when PAYE should have applied?

Employment-status errors can affect who should have accounted for tax and National Insurance and may create liabilities for the engager.

If the working relationship does not reflect genuine self-employment, the status should be reviewed rather than simply continuing CIS because that is how the worker was previously paid.

Reviewed & Updated

Updated:
18 August 2026
Topic:
Employment status
Content owner:
GO TAX REFUNDS
Primary guidance:
HMRC

CIS vs PAYE FAQs

Does a UTR mean I am self-employed?

No. A UTR is a tax reference. Employment status is determined separately.

Does CIS registration prove I am a subcontractor?

No. HMRC explicitly says CIS registration is irrelevant when deciding employment status for a particular engagement.

Can I be CIS for one job and PAYE for another?

Yes. Different engagements can produce different status outcomes depending on their actual terms.

Who decides whether PAYE should apply?

The engager must consider the worker's status when the worker is engaged, applying the tax status rules to the actual arrangement.

Official HMRC Sources

HMRC — CIS 340 HMRC — CIS and employees HMRC — Check Employment Status for Tax

Related CIS Guides

CIS Tax Refunds → CIS Registration → CIS Self Assessment → CIS Tax Hub →

Not sure whether your work is CIS or PAYE?

Get help reviewing your construction tax position and the records relevant to your tax return.

Contact Go Tax Refunds
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