2026 rule
HMRC states the nil-return obligation for mainstream contractors was reinstated from 6 April 2026.
Buyer-intent answers
HMRC · CIS · monthly returns
CIS Nil Returns in 2026: Decide Between a Nil Return and an Inactivity Request
An HMRC-backed monthly-control checklist for mainstream CIS contractors that made no subcontractor payments and need to avoid a missed-return penalty.
Primary query: CIS nil return inactivity request April 2026 contractor · Updated 2026-09-07
Direct answer
What should a CIS contractor do in a month when it has paid no subcontractors?
For mainstream CIS contractors, HMRC says the obligation to file a nil return was reinstated from 6 April 2026. If no subcontractor payments were made for the period, the contractor should either file a monthly return showing zero payments or tell HMRC that it has temporarily stopped using subcontractors through an inactivity request. Doing neither can lead to a late-filing penalty, so the no-payment decision should be treated as a monthly close control rather than simply leaving the return blank.
Practical sequence
What to do next
- 01
Close the subcontractor payment ledger for the CIS month and confirm whether any in-scope payments were actually made.
- 02
If payments were made, prepare the normal CIS monthly return and reconcile the listed subcontractors, deductions and employment-status declarations.
- 03
If no payments were made but subcontractor use may resume, file a nil return for the period or use the HMRC inactivity route where appropriate.
- 04
Record which route was used, the filing or inactivity confirmation and the period it covers.
- 05
Add a control for the next CIS period so an inactivity assumption is not carried forward after subcontractor payments restart.
- 06
Retain the supporting payment ledger and filing evidence with the monthly CIS close pack.
Decision facts
No-payment options
File a nil return or tell HMRC that subcontractor use has temporarily stopped through an inactivity request.
Penalty exposure
HMRC guidance says an outstanding monthly return can trigger escalating late-filing penalties.
Boundaries
- — The correct filing position depends on the contractor’s actual CIS status, payment activity and any valid inactivity period already notified to HMRC.
- — This page is an operational preflight, not tax advice; use the current HMRC CIS service and guidance for the live filing decision.
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