The domestic reverse charge has applied to construction services since 1 March 2021 and it is still getting invoices wrong five years later. The reason is that it borrows its scope from the Construction Industry Scheme without being part of it, so a business that gets CIS scope wrong gets VAT wrong on the same invoice. The default position also surprises people: absent a written notification from your customer, the reverse charge applies.
Guide · Updated August 2026
Under VAT Act 1994 section 55A, on a supply caught by the reverse charge the supplier does not charge VAT. The customer accounts for the VAT on the supply itself, as output tax on its own return, and recovers it as input tax in the same return where it is entitled to. No VAT moves between the two businesses. It applies to invoices with a tax point on or after 1 March 2021.
The policy purpose was to stop missing-trader fraud in construction labour chains. The practical effect on a legitimate subcontractor is that a float it used to hold has gone.
The reverse charge applies only where every one of the following holds:
Condition one is where most errors originate, because it imports CIS scope wholesale. Condition five is where the subtlety is: the charge applies where a return is required under the CIS regulations, not by reference to whether deductions are actually made. So a subcontractor with gross payment status — no deduction at all — is still inside the reverse charge.
Condition two rules out zero-rated work. New-build dwellings are zero-rated, so a subcontractor on a new-build housing site is outside the reverse charge on that work, and invoices at 0% in the normal way. The same subcontractor extending an occupied house next week is standard-rated and inside it. See the VAT rates guide for which is which.
That last list is the section 74(3) CIS exclusion list doing double duty. A business fitting CCTV and intruder alarms is outside CIS and outside the reverse charge; the same business running power to those cameras is inside both.
An end user is a VAT- and CIS-registered business that does not make onward supplies of the construction services it receives. A developer building to sell or let, or a retailer refitting its own shop, is typically the end user of the work it buys.
Here is the part that catches suppliers: the exclusion depends on the customer notifying the supplier in writing. HMRC's suggested wording is:
"We are an end user for the purposes of section 55A VAT Act 1994 reverse charge for building and construction services. Issue us with a normal VAT invoice, with VAT charged at the appropriate rate."
Once notified, the supplier need not seek further evidence. But absent notification the supplier must apply the reverse charge. The default is the reverse charge, not the normal charge. A subcontractor who assumes a big client "must be an end user" and adds 20% VAT has made an error on an invoice, and the customer has a corresponding error on its return.
An intermediary supplier is a VAT- and CIS-registered business that buys construction services and resupplies them without material alteration to a connected or linked end user. The qualifying link is either a relevant interest in the same land — landlord and tenant, typically — or membership of the same corporate group as defined by Companies Act 2006 section 1161. Written notification works the same way.
Practical instruction: get the notifications in writing, from every customer, before you invoice them, and keep them on file. One email per customer, once, saves reissuing invoices later. Test any individual job in the reverse charge checker.
All the normal VAT invoice particulars, plus:
HMRC's accepted forms of wording include "Reverse charge: VAT Act 1994 Section 55A applies" and "Reverse charge: Customer to pay the VAT to HMRC". Either is enough. What is not enough is a silent invoice with no VAT and no explanation — the customer's bookkeeper has no way to know whether it is a reverse charge supply, a zero-rated supply or an unregistered supplier.
Where the reverse-charge element is 5% or less of the total value of the supply, normal VAT rules may be applied to the whole supply. Three conditions: it requires agreement between both parties at the outset of the contract, it is calculated on overall contract value rather than invoice by invoice, and it does not apply where zero-rating is the predominant element.
It is a simplification for mixed contracts that are overwhelmingly something else — a facilities management contract with a small element of building work, for instance. It is not a way out of the reverse charge for a construction contract.
A labour-only subcontractor invoices £10,000 to a VAT-registered contractor who is not an end user, and is registered for CIS at the standard rate.
Before March 2021 the same invoice produced £12,000 in and £2,000 deducted: £10,000 banked, with the VAT to hand over later. The business now receives £8,000. If it is still budgeting on the old rhythm it is structurally short by a fifth.
Three consequences follow, and each has a response.
The VAT float is gone permanently. Before March 2021 a subcontractor held its output VAT for up to four months. Businesses that had quietly been using that money as working capital have to replace it from somewhere, and the only real answers are gross payment status and pricing.
You probably became a repayment trader. With no output VAT on sales but input VAT on materials, fuel, plant hire and overheads, your returns tend to produce refunds. If so, move to monthly VAT returns — it converts a quarterly refund into a monthly one and pulls a month of cash forward permanently.
The Flat Rate Scheme usually stops working. A labour-only subcontractor whose sales are all reverse-charged has, in effect, no VAT-inclusive turnover to apply a flat rate to, and its relevant goods spend is low by definition. The scheme remains potentially useful for a trade selling direct to domestic customers, outside CIS and outside the reverse charge — see the VAT rates guide.
Because the reverse charge follows CIS scope, and CIS follows the contract, there is only one reliable sequence:
Get step one wrong and you get VAT wrong on the same invoice, on both sides of it. That is why we treat CIS scope and VAT treatment as one review rather than two — the CIS guide covers step one properly.
What has changed on CIS and the reverse charge, the dates coming up, and one number worth checking on your own jobs. No spam, unsubscribe any time.
Not if all six reverse-charge conditions hold: the work is a construction operation within the CIS definition, it is standard-rated or reduced-rated, both of you are VAT registered, the customer is registered for CIS, the payment is reported within CIS, and the customer is neither an end user nor an intermediary supplier who has notified you in writing. In that case you invoice with no VAT and state that the customer must account for it. The important part is the default: if your customer has not notified you in writing that it is an end user or intermediary supplier, you must apply the reverse charge rather than assume normal VAT.
No. The reverse charge takes its scope from the CIS definition of construction operations but is not part of the scheme, and it applies where a return is required under the CIS regulations rather than by reference to whether deductions are actually made. A subcontractor with gross payment status suffers no CIS deduction and is still fully inside the reverse charge. So the invoice carries no VAT, states that the customer accounts for it, and shows the VAT amount or rate for information only. The two regimes answer different questions: gross payment status is about deductions from your payment, the reverse charge is about who accounts for the VAT.
An end user is a business registered for both VAT and CIS that does not make onward supplies of the construction services it receives — a developer building to sell or let, or a retailer having its own premises refitted. You do not decide it and you should not guess it: the exclusion depends on the customer notifying you in writing, and HMRC publishes suggested wording confirming end user status for the purposes of section 55A VAT Act 1994. Once you have that notification you can issue a normal VAT invoice and need not seek further evidence. Without it, the reverse charge is the default and applying VAT creates an error on both sides.
No, because the reverse charge only applies to supplies that are standard-rated at 20% or reduced-rated at 5%, and construction of a new dwelling is zero-rated. So a subcontractor on a new-build residential site invoices at 0% in the ordinary way, with no reverse charge wording. The distinction matters because the same trade may be zero-rated on Monday and reverse-charged on Tuesday depending on the site: extensions and alterations to existing occupied dwellings are standard-rated, and a standard-rated supply to a CIS-registered, VAT-registered contractor who is not an end user goes onto the reverse charge.
It is entirely normal. With reverse-charged sales you have no output VAT, but you still recover input VAT on materials, fuel, plant hire and overheads, so the return naturally produces a repayment. The fix for the cash-flow timing is to move to monthly VAT returns rather than quarterly, which converts a quarterly refund into a monthly one and permanently pulls a month of cash forward. It is also worth reviewing the Flat Rate Scheme if you are still on it, because with reverse-charged sales there is little VAT-inclusive turnover to apply a flat rate to and it usually stops being beneficial.
A free, no-obligation call about your CIS position, your VAT treatment and what is actually locked up. If we cannot save you anything, we will say so.
One short email: what has changed in CIS and construction VAT, the dates coming up, and one number worth checking on your own invoices. No spam, unsubscribe any time.