Making Tax Digital for Income Tax is now live for the first mandatory group. Sole traders and landlords whose qualifying income exceeded £50,000 on their 2024/25 tax return have generally been required to keep digital records and use compatible software since 6 April 2026, subject to HMRC exclusions and exemptions.
The first standard quarterly update deadline was 7 August 2026. Businesses that missed it should still send the update promptly: HMRC will not apply quarterly-update penalty points for 2026/27, but all required updates must be submitted before the 2026/27 tax return can be completed.
Across the first two phases of the MTD rollout, HMRC expects to mandate approximately 1.75 million customers into the new digital regime. However, recent industry reports and surveys reveal that nearly a third of sole traders remain entirely unaware of the MTD requirements or feel wholly unprepared for the upcoming changes.
To help you guide your clients through this transition, this guide outlines the statutory framework for the 2026/27 tax year, the strict new quarterly deadlines, and the temporary penalty waivers HMRC has introduced to ease the compliance burden.
The Statutory Framework: Finance Act 2026
The legal foundation for the new digital requirements sits within Schedule A1 of the Taxes Management Act 1970 (TMA 1970). The Finance Act 2026 substantially amended these provisions to give HMRC the statutory power to mandate electronic returns and digital record-keeping for “relevant persons” carrying on a “relevant activity” (self-employment or property businesses).
The legislation effectively forces sole traders and landlords out of the traditional annual Self Assessment cycle and into a quarterly digital reporting regime, provided they breach specific income thresholds.
The Phased Mandation Thresholds
HMRC assesses a taxpayer’s eligibility for MTD for ITSA based on their “qualifying income. This is the total gross turnover from all self-employment and property businesses before you deduct any expenses.
The government has structured the mandation in three distinct phases:
- 6 April 2026: Sole traders and landlords must operate MTD if their qualifying income exceeds £50,000.
- 6 April 2027: The threshold drops, mandating those with a qualifying income exceeding £30,000.
- 6 April 2028: The threshold drops again, capturing those with a qualifying income exceeding £20,000.
If a sole trader’s 2024/25 tax return showed a qualifying income above £50,000, they are legally compelled to join the regime on 6 April 2026.
The Core Requirements: Digital Records and Quarterly Updates
Once mandated, taxpayers can no longer keep paper records or wait until January to calculate their tax liability. They must comply with two core ongoing obligations.
1. Creating Digital Records
Taxpayers must use MTD-compatible software to create, store, and correct digital records of their income and expenses. If a client insists on using spreadsheets, they can continue to do so, provided they use MTD-compliant “bridging software” to link their spreadsheets to HMRC’s systems.
For every business transaction, the digital record must capture:
- The amount.
- The date the income was received or the expense occurred.
- The category of the income or expense.
2. Quarterly Updates
Taxpayers must submit digital quarterly updates to HMRC summarising their business income and expenses. HMRC has designed these updates to be cumulative.
“Rather than a total for the 3-month period covered within the update, each update will be a cumulative total of income and expenses accumulated during the tax year to-date. This will remove the burden upon customers of having to resubmit a previous update where corrections to previously submitted transactions are required.”
For those mandated on 6 April 2026 (assuming a standard 5 April accounting period end), the strict statutory deadlines for the first year are:
- Update 1: 7 August 2026.
- Update 2: 7 November 2026.
- Update 3: 7 February 2027.
- Update 4: 7 May 2027.
After submitting the final quarterly update, the taxpayer must still submit a final year-end declaration and pay any tax due by the standard 31 January deadline.
Penalties and the 2026/27 Waiver
To support businesses during the first mandatory year, HMRC has adjusted its penalty regime.
HMRC is replacing the old penalty system with a points-based system for late submissions, where a taxpayer receives a point for a missed deadline rather than an immediate fine. Crucially, HMRC has confirmed a penalty waiver for the first year: they will not apply penalty points for late quarterly updates during the 2026/27 tax year.
However, you must warn clients that this leniency only applies to the updates. If a taxpayer is late paying their actual tax bill, HMRC will still issue a late payment penalty, which scales proportionately to how long the debt remains unpaid.
Summary of MTD for ITSA Obligations (2026/27)
| Requirement / Element | Affected Party | Provision / Deadline | Consequence / Outcome |
|---|---|---|---|
| Phase 1 Mandation | Sole traders/landlords> £50k | 6 April 2026 | Must commence MTD digital record keeping and reporting. |
| Qualifying Income | All self-employed / landlords | Sch A1 TMA 1970 | Assessed on gross turnover before expenses across all trades/properties. |
| Digital Records | Mandated taxpayers | FA 2026 amendments | Must record amount, date, and category digitally via compatible software. |
| Quarterly Updates | Mandated taxpayers | First deadline: 7 August 2026 | Must submit cumulative totals of income and expenses every 3 months. |
| Late Update Penalties | Mandated taxpayers | 2026/27 Tax Year | Points-based penalties are waived for late updates in the first year. |
| Late Payment Penalties | Mandated taxpayers | 31 January (standard) | Fully enforced; proportionate penalties apply for late tax payments. |
Next steps: Audit your sole trader and landlord client lists to identify everyone whose 2024/25 gross income exceeded £50,000, and complete software onboarding and correct any gaps in digital record-keeping from 6 April 2026 transition.
Official August 2026 update
HMRC confirmed that the first standard quarterly update was due on 7 August 2026 and that no penalty points will be issued for late quarterly updates during 2026/27. See HMRC’s first-quarterly-update announcement and the quarterly update guidance.