Are Changes in CITB Levy on the Horizon?
At Chartergates, we receive a significant number of enquiries relating to the Construction Industry Training Board (CITB) Levy.
While the nature of these enquiries varies, a recurring theme has emerged in recent months: labour suppliers that are registered and paying the levy are increasingly questioning why other companies providing similar services appear not to be registered.
A More Competitive Labour Supply Market
Recent changes to the Construction Industry Scheme (CIS), coupled with the introduction of joint and several liability provisions, have created an increasingly competitive marketplace for the labour supply sector.
As margins tighten, businesses that are required to pay the CITB Levy can feel disadvantaged when competing against organisations that are not registered.
How CITB Identifies Potentially Liable Businesses
Traditionally, CITB identifies potentially liable businesses and contacts them directly.
Companies are invited to provide information about their activities, after which CITB may conduct a verification meeting or audit before determining whether registration is required.
Similar Businesses Can Face Different Levy Obligations
While this process is intended to ensure compliance, it can create situations where two businesses, both with CIS Gross Payment Status, offer virtually identical services, yet only one is contributing to the levy.
A New Section in the 2026 Levy Return
A notable development has appeared in the 2026 Levy Return.
Those who have already completed the return may have noticed the introduction of a new Section 3b, which also appears within the payments section of the online return.
Additional Information About Labour Supply Payments
This section requires levy-paying businesses to provide additional information relating to payments made to labour agencies, umbrella companies and similar organisations.
Specifically, businesses must now disclose:
- payments made under the CIS to labour agencies, umbrella companies, CIS payroll providers or similar organisations holding HMRC Gross Payment Status; and
- payments made outside of the CIS to labour agencies, umbrella companies or similar organisations.
Why CITB Is Collecting This Information
According to CITB, this information is being collected to better understand labour supply trends, assess the prevalence of different labour engagement models and support future levy strategy planning.
What Could the Additional Data Lead To?
Whilst CITB has stated that the purpose is informational, it is worth noting that the organisation has regularly reviewed and amended its funding criteria, how funding is distributed, and its levy arrangements over the years.
Given the increased focus on labour supply chains, many businesses are asking what this additional data collection could lead to.
Could the CITB Levy Change Again?
Could future returns require businesses to identify all Gross Payment Status subcontractors?
Might the CITB use the information gathered to approach labour suppliers that are not currently registered?
Or could future reforms alter the levy calculation itself to include payments made to Gross Payment Status subcontractors?
The Questions Remain Speculative
At this stage, these questions remain speculative.
However, the introduction of Section 3b suggests that the CITB is taking a much closer look at labour supply arrangements within the construction industry.
Businesses should therefore pay close attention to future consultations and levy announcements, as further changes may be on the horizon.
How We Can Help With the CITB Levy
Whether you are already registered with the CITB, have received correspondence from the CITB regarding a potential levy liability, or simply want to understand your obligations, Chartergates can help.
View our CITB Levy Advice page for more insight.
Our CITB Levy Services
We have extensive experience advising businesses across the construction and labour supply sectors on all aspects of the CITB Levy, including:
- determining whether a business is required to register with the CITB;
- reviewing business activities and labour supply arrangements to assess levy liability;
- preparing for and supporting clients through the CITB verification meetings and audits; and
- challenging incorrect levy assessments and resolving disputes with the CITB.
Why Early Advice Matters
As the construction labour market continues to evolve and the CITB gathers more information on labour supply arrangements, it is becoming increasingly important for businesses to understand both their current obligations and any potential future exposure.
Seeking advice early can help avoid unexpected liabilities and ensure your business remains compliant while remaining competitive.
Speak to Chartergates About Your CITB Position
If you would like to discuss your CITB position or have concerns about how recent changes may affect your business, please contact the Chartergates team for a confidential discussion.
Disclaimer
Chartergate Legal Services Ltd has drafted this email update to provide you with a general overview of the relevant law and developments at the date of sending only. This email is provided as a general overview and should be taken as such. It is not a substitute for professional advice that is specific to your circumstances and should not be relied upon as such.
