IR35 AccountantsStatus Determination Disputes
Help disputing a Status Determination Statement you believe is wrong, using the client-led disagreement process, evidence packs and the 45-day window the rules give your client to respond.
Client-led disagreement process · 45 days for the client to respond · Silence shifts the liability back to the client
Status Determination Disputes: what you need to know
When a medium or large engager decides your role is inside IR35, the Status Determination Statement it issues is not the end of the conversation. The off-payroll legislation builds in a client-led status disagreement process: you make representations, and the client has 45 days to either issue a fresh determination or explain why the original stands. Most contractors never use it, or use it badly, with a two-line email that the client can dismiss without engaging.
A challenge that works reads like a legal submission, because functionally it is one. It takes each reason stated in the SDS and answers it with the contract clause, the working-practice fact or the authority that contradicts it. Where the determination was made on a role basis rather than your individual circumstances, the argument shifts to the client's duty of reasonable care, which blanket decisions strain. We draft these representations and assemble the evidence pack behind them.
Timing matters more than most contractors realise. A determination accepted quietly becomes the operative position for the whole engagement, and unwinding it later is far harder than contesting it within the process the legislation provides. The 2026 threshold change adds a second front: where an engager has become small, the decision returns to your company entirely and the old SDS stops governing. We tell you within the first conversation whether your challenge has substance or whether the determination is, on the facts, correct.
What you get
Representations that engage the reasons
A drafted rebuttal that answers the SDS point by point with evidence and authority, which is what forces a client to genuinely reconsider rather than rubber-stamp.
The 45-day lever used properly
We track the statutory clock and cite the consequence of silence accurately: a client that does not respond in time carries the liability itself until it does.
Blanket decisions confronted
Role-based determinations sit uneasily with the reasonable-care duty. A properly evidenced individual case is the strongest tool for reopening one.
Honest triage before you spend
Not every SDS is wrong. We assess your prospects first and say plainly when the determination would survive scrutiny.
What's covered under status determination disputes
We handle the full range of work that sits within status determination disputes, including:
SDS review and rebuttal drafting
A specialist reading of the determination and a formal written representation that addresses each stated reason with evidence and case law.
Blanket determination challenges
Individual-circumstances arguments against role-based decisions, built on the engager's statutory duty to take reasonable care over each determination.
Status evidence pack preparation
Contracts, correspondence, substitution records and working-practice statements organised into a pack the client cannot reasonably wave away.
Missing or invalid SDS advice
Analysis of where the PAYE obligation and liability sit when no valid statement was issued, which often changes the negotiating position entirely.
Supply chain liability mapping
A clear picture of who owes what between client, agency and fee-payer, including how the offset rules introduced in April 2024 affect any exposure.
Post-2026 re-determination support
Help for contractors whose engagers became small under the £15m and £7.5m thresholds, covering the transition and the fresh determination your own company now makes.
Who this is for
Disputes we take on include:
- A project manager caught in a blanket inside determination applied to every contractor on a programme, regardless of how differently each role operates.
- A consultant whose SDS gives reasons that contradict the signed contract, citing supervision arrangements that have never existed in practice.
- A contractor whose client issued no SDS at all yet instructed the agency to deduct PAYE, leaving the chain's obligations unclear.
- A specialist whose representations were rejected with a single sentence and who wants the response tested against the client's duty to consider them properly.
- A contractor whose engager became small under the April 2026 thresholds and needs the transition handled so the old determination is not applied beyond its life.
How an engagement works
Send us the determination
Share the SDS, the stated reasons and where you are in the 45-day window, and we take it from there.
Fixed written quote in 48 hours
We come back with a fixed written quote for the challenge, prioritised when your deadline is close.
Costed scope up front
The quote sets out exactly what the challenge will involve at a fixed price before any drafting begins.
We run the dispute with you
We prepare the representations, manage the 45-day deadline and handle the client's response, briefing you at each step.
Read before you decide
The guides library covers the rules behind this service in depth.