Locum GPs

It depends on the working arrangement, and there is no special rule for locum GPs. HMRC's ESM4062 warns specifically that where a locum stands in for another doctor it must not be assumed they share that doctor's status — some so-called locums are in fact assistants, with employment income and Class 1 National Insurance. The ordinary tests apply: control, personal service and substitution, financial risk, mutuality of obligation, and whether you are in business on your own account. It is established from the contractual terms, not from what the invoice says.

Any practice with a registered patient list, because it is a public authority for the purposes of Chapter 10 — and there is no small-client exemption for a public authority. That means even a two-partner practice must determine your status and issue a Status Determination Statement if you work through a personal service company. This has been the position since 6 April 2017, so if you have been given no determinations by practices you have worked for, that is their gap rather than yours.

Through GP locum forms A and B, where you elect to pension the work. Keep it separate from any other role: if you also do out-of-hours work for a provider, or self-employed ICB work, you are a Type 2 medical practitioner in that role and NHSBSA is explicit that it must not be recorded on the locum forms. Getting that separation right is what produces a complete and correct pension record rather than one that has to be untangled later.

It is a modelling question, and the off-payroll rules change the answer materially in this sector. If most of your work is for practices with registered patient lists — all of which are public authorities with no size exemption — a large share of your engagements may be determined as inside the rules, which removes much of the benefit of the company while keeping all of its administration. That is worth establishing before you incorporate rather than afterwards. We will model both positions on your actual mix of work rather than on the general case, because the answer genuinely differs depending on how much of your income comes from practices with patient lists.

From 6 April 2026 umbrella companies are no longer legally responsible for operating PAYE on payments to workers they employ. Responsibility moves to the recruitment agency supplying the worker, or where there is no agency, to the end client, with joint and several liability. It is a separate regime from off-payroll working and does not change Chapter 10, but it does change who carries the risk in a chain that includes an umbrella. If you are paid through one, it is worth knowing whether an agency sits in the chain, because that decides whether the PAYE responsibility now sits with them or with the practice engaging you.