New IR35 Legislation Published on 11th July 2019


Following on from my previous blog regarding Off-payroll working (IR35) in the private sector,  on 11th July 2019 HMRC published draft legislation for the off-payroll working rules affecting PSC contractors coming into force on 6th April 2020.  The legislation is primarily updating existing off-payroll legislation drafted for the 2017 roll-out in the public sector.  The new rules will apply to both private & public sectors.

This is the biggest legislative change to hit our sector and unfortunately there is no simple right or wrong answer however we can provide guidance so now is not the time to be a “Chicken Licken”, preparation is most definitely the key and working practices need to be reviewed carefully.

Church International, as members of APSCo, have access to comprehensive guidance and assistance and I personally have experience of managing the effects of IR35 since it was first introduced back in 2000 (from both client and recruiter sides of the fence).

IR35 has never been clear cut and without its challenges and it’s disappointing that the government are still going ahead with this piece of legislation, however by all parties in the supply chain working together in partnership and steering clear of blanket determinations, affirmative action can be taken to prevent ‘the sky from falling’ and provide opportunites for:

  1. Audit of contingent workforce and ensure IR35 compliance
  2. Change and to move away from traditional T&M resources to “Output Based” / SOWs model
  3. Implement a more Agile way of working
  4. Engaging the best and most talented Off-payroll contractors


We are communicating with our clients and contractors as we have a step by step process planned to ensure that they are in the best possible position come April 2020 and to help our clients manage the implementation of the off-payroll (IR35) reforms as part of our TLC offering here at Church International so that they can continue to attract the best Off-payroll talent.

In the meantime, if you are a client looking at the implication of IR35 on your organisation and the impact on your contingent workforce, or a contractor who wants to gain more insight into the implications of IR35 on your continued contract career, please register your interest in receiving our IR35 updates or taking part in our regular briefings by calling me on 01622 620718, emailing me at or messaging me via LinkedIn



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