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7 August 2026: the first real test for Making Tax Digital for Income Tax
 

The first quarterly update is not a tax return. But neither is it an optional exercise.

A guide for sole traders, CIS subcontractors and landlords in the United Kingdom

Updated: 25 July 2026

For several years, Making Tax Digital for Income Tax was one of those tax reforms close enough to be discussed, but distant enough to be postponed.

That stage has ended.

On 6 April 2026, the first wave of sole traders and landlords entered the new regime. The first standard reporting period — 6 April to 5 July — has ended, and the first quarterly update must reach HMRC by 7 August 2026. For those using calendar quarters, the period covered is 1 April to 30 June, but the deadline remains the same. HMRC announced on 23 July that more than 864,000 people had already signed up for MTD Income Tax ahead of the first national deadline. (GOV.UK)

The date does not create a new Income Tax payment. It does not turn every quarter into a mini Self Assessment and does not require annual accounts to be completed after only three months.

Its significance is deeper.

For the first time, a very large group of taxpayers must demonstrate that their tax records can be built digitally during the year, rather than reconstructed after it has ended from bank statements, photographs, incomplete invoices and explanations provided from memory.

MTD does not only change how information reaches HMRC. It changes when the records must become usable.

The first quarterly update is therefore a test of the entire system: correctly identifying the obligation, enrolling the client, authorising the software, collecting documents, classifying transactions and successfully submitting the information to HMRC.

If one of these components does not work, the problem does not disappear after 7 August. It is carried into the next quarter, where it will meet another three months of transactions.
 

The conclusion at the outset

From 6 April 2026, MTD Income Tax applies, in principle, to a person registered for Self Assessment who receives income from self-employment, property, or both, and whose qualifying income for the 2024/25 tax year exceeded £50,000.

The threshold does not relate to the profit remaining after expenses. It is based on eligible gross income — turnover from self-employment and relevant gross property income — before costs are deducted. HMRC will extend the regime to people with qualifying income above £30,000 from April 2027 and above £20,000 from April 2028. (GOV.UK)

People within the regime must keep digital records using compatible software, submit quarterly updates for the relevant activities and file their tax return at the end of the year through the same MTD ecosystem. (GOV.UK)

The first update is not a tax return and does not require all year-end accounting or tax adjustments to be completed. HMRC receives category totals for income and expenses, not every individual invoice or receipt. However, an update must still be submitted even where there was no income or expenditure during the relevant period. (GOV.UK)

For the 2026/27 tax year, HMRC will not award penalty points for late quarterly updates. This is a transitional measure, not a suspension of the obligation. The updates must be submitted before the annual tax return can be filed, while the rules for late tax returns and late payments continue to apply. (GOV.UK)
 

Who enters the first wave?

The most dangerous error at the beginning of the regime is using profit to test the £50,000 threshold.

Qualifying income is the total relevant gross income from self-employment and property. Where there are several businesses or sources of property income, they are combined. PAYE salary, pensions, dividends — including those received from the person’s own company — and an individual partner’s share of partnership profits are not included in this calculation. (GOV.UK)

Assume that a CIS subcontractor had gross self-employment income of £38,000 and gross rental income of £16,000 during 2024/25.

Qualifying income is £54,000.

The fact that taxable profit remaining after tools, travel, insurance, property costs and other expenses is considerably lower does not alter the entry test. Nor does the fact that each source, considered separately, is below £50,000.

By contrast, a person with £46,000 of gross self-employment income, a £30,000 PAYE salary and £8,000 of dividends has qualifying income of £46,000 in principle, not £84,000. The other income will matter for the final tax calculation, but not for the MTD threshold. (GOV.UK)

This is one reason why the obligation should not be determined from memory or by taking a quick glance at the declared profit.

The 2024/25 Self Assessment must be checked source by source.
 

The HMRC letter does not create the obligation

HMRC reviews previous tax returns and normally writes to people who appear to exceed the relevant threshold.

But the letter is not the instrument that creates the obligation.

HMRC makes clear that responsibility for checking qualifying income and entering the system on time remains with the taxpayer, even if the notification has not arrived. (GOV.UK)

This distinction matters in practice.

A letter may be sent to an old address. It may be ignored, lost or sent to someone who has changed accountants. A Self Assessment may be amended, and that amendment may change the person’s MTD position.

The absence of an envelope is not the same as the absence of an obligation.

What does the quarterly update actually transmit?

The update is produced by software from the activity’s digital records.

At each deadline, the software adds together the amounts recorded in the relevant income and expense categories and submits the totals to HMRC for each relevant self-employment or property business. Copies of invoices, receipts or every line from the bank statement are not submitted. Supporting documents must nevertheless be retained to support the records and final tax return. (GOV.UK)

The updates are cumulative.

The first standard update covers 6 April to 5 July. The second will cover the period from 6 April to 5 October, not only the months from July to October. The third will cover 6 April to 5 January.

This structure allows an error discovered later to be corrected in the digital records and reflected in the next cumulative total without resubmitting every previous update. (GOV.UK)

Flexibility should not be confused with a lack of discipline.

A transaction classified provisionally may be corrected. A year-end tax adjustment may be made later. But a completely missing receipt, an undisclosed bank account or a set of documents that never reached the software are not adjustments. They are incomplete records.

DCTaxAgent Insight

MTD allows figures to be refined. It does not justify improvised records.

Why the update is not a mini Self Assessment

HMRC states that not all accounting or tax adjustments need to be completed before a quarterly update is submitted. (GOV.UK)

This means that submission should not be delayed simply because items such as the final private-use proportion, capital allowances, accruals, prepayments or certain year-end reliefs have not yet been determined.

But the distinction must be applied carefully.

A final calculation for the mixed use of a vehicle can be refined at the end.

A completely missing invoice must be requested.

An unknown transaction can be investigated and corrected.

An entire month of income that has not yet been entered should not be treated as a future adjustment.

MTD does not require quarterly accounting perfection. It requires digital records that are sufficiently complete and credible for the submitted summary to make sense.

What happens after submission?

After the update is submitted, the software or HMRC account may display an estimated tax liability relating to self-employment and property income.

The estimate may also use certain information already known to HMRC. However, it may be less accurate if the person has other income that has not yet been entered, if the accounting period is not aligned with the tax year or if final adjustments are missing. (GOV.UK)

This is not a final tax calculation.

It does not replace the tax return and does not automatically create a new payment on 7 August.

For the first MTD year, the tax return for 2026/27 must be filed through compatible software by 31 January 2028, together with the adjustments, reliefs, other income and relevant final information. (GOV.UK)

The estimate may nevertheless be very useful.

For a CIS subcontractor, it may indicate whether gross income, expenses and CIS deductions have been reconciled coherently.

For a landlord, it may highlight that income is rising faster than deductible expenditure and that the tax reserve should be adjusted.

But the quality of the estimate cannot exceed the quality of the records from which it was produced.

Two calendars and a choice that should not be made automatically

MTD permits standard periods and calendar periods.

The standard periods follow the tax year: 6 April to 5 July, 6 April to 5 October, 6 April to 5 January and 6 April to 5 April.

For businesses with an accounting period from 1 April to 31 March, calendar periods may be more natural: 1 April to 30 June, 1 April to 30 September, 1 April to 31 December and 1 April to 31 March.

The deadlines are the same under both options: 7 August, 7 November, 7 February and 7 May. (GOV.UK)

The calendar-period election must be made in the software for each source before the first update is submitted. Once a quarterly update has been submitted, the period cannot be changed for that tax year. (GOV.UK)

This is not merely a presentation option.

If the records are managed monthly for periods from 1 April to 31 March, but the software reports using dates from 6 April to 5 April, the five-day differences may create additional reconciliation work at every deadline.

A poor choice at the first submission can turn four simple updates into four unnecessary realignment exercises.

Enrolment, authorisation and software are three different things

A taxpayer may have an HMRC account, an accountant authorised for Self Assessment and a software subscription without the MTD route being complete.

For clients represented by an agent, the existing Self Assessment relationship may be recognised, but it must appear in the Agent Services Account. In addition, authorisation does not automatically enrol the client in MTD Income Tax: each client must be enrolled individually. (GOV.UK)

The software must then be authorised to communicate with HMRC and configured for the correct income sources.

In practice, an agent may be fully authorised to file the traditional Self Assessment but still be unable to submit an MTD update because:

the client has not been enrolled;

the relevant activity does not appear correctly;

the authority has not been transferred into the Agent Services Account;

the software is not connected;

the authentication has expired.

These are technical problems, but they have tax consequences. They must be discovered before the day of the deadline.

A bank feed is not an accountant

Connecting the bank account to the software is useful. It does not, however, complete the records.

The software cannot always know whether a payment to a supermarket represents materials, subsistence, a mixed purchase or a personal expense. It cannot decide by itself whether a cash deposit is income, capital introduced or a transfer between accounts.

It cannot create a missing invoice or confirm that income received through a platform was recorded gross, before commission.

For a CIS subcontractor, the amount received in the bank may be net of the CIS deduction, while the records must be reconciled to the gross invoice and CIS statement. For a landlord, a mortgage payment is not automatically equivalent to a deductible expense, and personal and property costs must be separated.

The bank feed reduces manual data entry.

It does not replace accounting judgement, documents or reconciliation.

What are digital records?

The rules require digital records to be created and maintained for the business’s income and expenses.

The entries must be created before the quarterly deadline or before submission where the update is sent early, and they should be made as close as possible to the transaction date. If a person enters the system after the beginning of the year, the records must be brought up to date from the start of the relevant period. (GOV.UK)

The concept does not necessarily mean that every document must exist exclusively in digital form.

Original invoices and receipts may continue to exist on paper. The obligation is for the required tax information to be recorded digitally and to move through the MTD-compatible process without uncontrolled manual reconstruction.

A spreadsheet may form part of the system, but links between applications must be maintained in accordance with the digital-link rules. Repeated manual copying of totals between files and software may undermine the very trail that the reform is intended to create.

Landlords with jointly owned properties

For jointly let properties, HMRC allows quarterly updates to contain either income and expenses or income only.

If the landlord chooses not to include expenses for the jointly owned property during the year, those expenses must be added after year-end by resubmitting the fourth update before the tax return. For exclusively owned properties, the corresponding income and expenses must be included in the quarterly updates. (GOV.UK)

This simplification may reduce the quarterly workload, but it does not remove the need for documentation.

Agent fees, service charges, insurance, repairs and finance costs must still be analysed and supported.

What does the absence of penalties in the first year mean?

In 2026/27, a quarterly update submitted after the deadline does not generate penalty points.

That is the correct part of the message.

The dangerous part is the conclusion that the quarter may be ignored.

HMRC requires digital records to be maintained and all quarterly updates to be submitted before the annual tax return can be filed. Penalties for filing the tax return late and paying tax late have not been removed. (GOV.UK)

From later years, quarterly delays enter the points system. The person receives one point for each missed deadline, and a £200 penalty is imposed when the four-point threshold is reached. Every further missed deadline while the threshold remains active may generate another £200 penalty. (GOV.UK)

But in the first year, the greatest risk may not be the penalty.

It is accumulation.

The first update covers only the beginning of the year. If it remains unresolved, the second update does not start from zero. Because it is cumulative, it must repair the first few months and add the next period.

After two or three ignored deadlines, what appeared to be a saving of time becomes the same annual reconstruction that MTD was designed to replace — except that it must now be completed before the tax return can be submitted.

Exemption is not granted simply because digital reporting is inconvenient

There are automatic exemptions and circumstances in which an application must be made.

Digital exclusion may be recognised where it is not reasonable for the person to use compatible software because of age, health, disability, religious beliefs incompatible with the use of electronic communications or a genuine lack of internet access. HMRC considers the person’s individual circumstances. (GOV.UK)

By contrast, HMRC expressly states that it will not grant an exemption where the only argument is that the person previously filed paper returns, does not understand accounting software, has few transactions or will incur additional time and costs. (GOV.UK)

MTD may be inconvenient.

Inconvenience is not, by itself, digital exclusion.

What must be done before 7 August?

By the deadline, the objective is not to prepare perfect annual accounts.

The objective is to complete the first cycle in a controlled manner.

The 2024/25 Self Assessment must first be reviewed to establish qualifying income. It must then be confirmed that the person is enrolled, that all relevant activities appear in MTD, that the agent authority is operational and that the software can communicate successfully with HMRC.

The records must then be brought up to date to 5 July or 30 June, depending on the chosen period. Relevant bank accounts and cards must be reconciled, cash receipts included, missing documents requested, and personal transactions separated from business transactions.

Before submission, the reporting period must be checked again. Once the first update has been submitted, the choice for that tax year cannot be changed.

A final review should provide clear answers to only a few questions:

  1. Is the person genuinely required to use MTD from April 2026?

  2. Are all relevant sources active and linked correctly?

  3. Are the software and agent authorisation working?

  4. Is the standard or calendar period the correct choice?

  5. Are the known income and expenses recorded and reconciled?

  6. Has the confirmation of submission to HMRC been retained?

If the answer to any of them is “we do not know”, the process is not complete.

DCTaxAgent Insight: not four returns, but one process

MTD Income Tax can be managed badly as four separate emergencies.

Or it can be managed well as one annual process divided into predictable stages.

Records are created during the year. Reconciliation takes place regularly. Cumulative updates report progress. Adjustments, reliefs and the tax return are completed at the end.

This approach changes the value of accounting.

A missing invoice is requested after a few weeks, not after 15 months.

An unknown receipt is explained while the taxpayer still remembers it.

A missing CIS statement is requested before the contractor becomes difficult to contact.

A landlord sees earlier that income is rising and the tax reserve is insufficient.

The quarterly update is only the visible result.

The real value lies in the discipline that produces it.

Conclusion: 7 August is not about perfection. It is about control.

The first quarterly update is not a tax return and does not require the tax year to be closed after three months.

But it requires something that the old system allowed many taxpayers to postpone:

digital records that are sufficiently complete to produce credible figures during the year.

By 7 August, the person must be correctly assessed, enrolled, connected through compatible software and able to submit the update for the appropriate period.

The fact that HMRC does not award penalty points for quarterly updates in the first year provides room for adjustment.

It does not provide an exemption from the obligation.

The first period is probably the simplest test the new system will offer. It covers only the first few months of the year, and problems can still be isolated and corrected.

If the test is ignored, the next update will contain more transactions, more uncertainty and less time.

7 August 2026 is not merely the first MTD deadline. It is the date on which tax digitalisation stops being a future reform and becomes part of everyday tax administration.

How DCTaxAgent can help

DCTaxAgent can check whether you fall within MTD Income Tax, calculate qualifying income and configure the process before the first deadline.

Support may include reviewing the 2024/25 Self Assessment, registering for MTD, configuring the software, organising digital records, reconciling bank accounts, recording CIS deductions correctly, managing records for landlords and submitting quarterly updates.

The objective is not merely to file on time.

It is to build a system in which the quarterly obligation becomes a natural consequence of accurate records, rather than a new emergency every three months.

WhatsApp: 07587 532646
Website: www.dctaxagent.co.uk

Disclaimer

This article is provided solely for general information and educational purposes.

It does not constitute tax, accounting, legal or technology advice tailored to a particular person or business.

The MTD obligation depends on qualifying income, the nature and number of income sources, tax residence, any exemptions, information contained in previous returns and individual circumstances.

The rules and deadlines presented are those published and applicable as at 25 July 2026. The taxpayer’s position and HMRC guidance should be checked before registration or submission of an update.

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