UK VAT for Locum Doctors 2026/27 — RCB 6 Refund Claims

HMRC’s Revenue and Customs Brief 6 (2026) says that supplies of GMC-registered locum doctors may fall within the VAT exemption for the provision of a deputy. The position can apply when an employment business supplies the locum doctor, but it is limited to a registered medical practitioner performing a role that must be carried out by that practitioner.

This is a specific HMRC policy position, not a blanket exemption for every temporary healthcare worker or staffing invoice. If standard-rate VAT was charged on an affected supply, the person who made the supply and charged the output tax may be able to seek a refund for eligible periods. HMRC will assess claims individually and can refuse an amount that would create unjust enrichment.

What RCB 6 changes

The specific exemption is in Item 5, Group 7, Schedule 9 of the VAT Act 1994: the provision of a deputy for a person registered in the register of medical practitioners. HMRC’s earlier position treated supplies by employment businesses as standard-rated staff supplies. After the First-tier Tribunal decision in Isle of Wight NHS Foundation Trust v HMRC, HMRC reviewed the position and published RCB 6.

HMRC now says that supplies of GMC-registered locum doctors may fall within the exemption, including supplies made through an employment business. The wording matters: it is not permission to remove VAT from every agency, consultancy or healthcare invoice without checking the individual supplied and the role performed.

The table is a screening aid, not a legal classification. The contract, actual role, registration and supply chain still need to be reviewed.

Who is the relevant medical practitioner?

For this RCB 6 position, “registered locum doctor” means an individual registered with the General Medical Council and performing medical services in that professional capacity. The role supplied must be one that must be carried out by a registered medical practitioner.

Do not extend the conclusion to a person merely because they work in a hospital, wear a clinical uniform or have another professional registration. HMRC specifically excludes other health professionals from this particular position. If an agency supplies a mixed workforce, separate the qualifying doctor supplies from other staff rather than applying one VAT treatment to the whole invoice.

VAT Notice 701/57 remains the relevant HMRC notice for health professionals and pharmaceutical products. Use the notice and the RCB together, and preserve the evidence that supports the professional status and the nature of the role.

Can a supplier claim VAT charged in earlier periods?

Possibly. HMRC says a claim may be available where:

• the supplier made a supply of locum doctors;
• standard-rate output tax was charged;
• the supplier now considers the supplies should have been exempt; and
• the overdeclared output tax relates to supplies made within the last four years.

Only the person who made the supply and charged the output tax can claim. A hospital or agency customer cannot turn its purchase invoice into its own output-tax refund claim. The parties should reconcile invoices, VAT returns, payments and any credit or reimbursement arrangement before deciding who has the claim.

The normal VAT correction routes depend on the amount and the correction rules. Depending on the circumstances, the supplier may adjust the return for the period in which the overdeclared tax is discovered or submit an error correction notification using form VAT652. The claimant must explain the basis of the claim, the calculation, the relevant prescribed accounting periods and the supporting records. Follow the current RCB 6 instructions and VAT Notice 700/45 rather than reusing instructions from an older medical-staff brief.

Unjust enrichment and customer reimbursement

HMRC will not pay a claim that would unjustly enrich the claimant. In plain terms, a supplier should not keep a refund of VAT that was recovered from a customer without considering how the overpaid amount should be handled.

The claim therefore needs more than an invoice total. Keep a schedule showing the affected supplies, output VAT originally declared, the customer treatment, any credit or reimbursement made or planned, and the net amount claimed. HMRC can request documents and may examine whether the overdeclared VAT was correctly accounted for through the supply chain.

There is no universal rule in this guide that tells every supplier to issue a credit note or repay a particular customer. The correct treatment depends on the contract, who bore the cost, how the VAT was accounted for and the applicable correction route.

Input tax and partial exemption

If supplies previously treated as taxable are instead treated as exempt, review the input VAT recovered in connection with those supplies. Exempt supplies can affect partial-exemption calculations and the amount of input tax that can be retained.

HMRC says the amount claimed must be the net amount after the appropriate input-tax consequences. A supplier should therefore avoid calculating the claim as “all VAT charged to customers” without revisiting associated costs, partial-exemption methods and adjustments. VAT Notice 706 explains the wider partial-exemption framework, while VAT Notice 700/45 covers correction and claim procedures.

A practical RCB 6 review checklist

Frequently Asked Questions

Evidence and decision checks

A reliable uk locum doctors vat 2026 27 review starts by fixing the tax year and the date on which the relevant event happened. Record the person's or business's status, the income or transaction category, the amount before tax, tax already withheld, and any election or claim being relied on. Do not combine a headline figure with a final liability: the result can change when another income source, a payment date, an ownership interest or a qualifying condition is added.

Keep the source documents behind every important input. Depending on the subject, that may include payslips, invoices, bank statements, contracts, provider statements, travel records, HMRC notices, payroll submissions, valuations or correspondence. Where an amount is apportioned, write down the method and retain the underlying total. If a correction is made, preserve the original figure and explain the reason, date and evidence for the replacement.

Before relying on the result, check the current official guidance for the same tax year and jurisdiction. Distinguish enacted law from a consultation, draft measure, announcement or future proposal, and record the effective date. Reconcile the final estimate to the relevant return, payroll record or HMRC account. A calculator or explanatory guide can support a decision, but it cannot replace the eligibility test or the official filing and payment process.

Evidence and decision checks

A reliable uk locum doctors vat 2026 27 review starts by fixing the tax year and the date on which the relevant event happened. Record the person's or business's status, the income or transaction category, the amount before tax, tax already withheld, and any election or claim being relied on. Do not combine a headline figure with a final liability: the result can change when another income source, a payment date, an ownership interest or a qualifying condition is added.

Keep the source documents behind every important input. Depending on the subject, that may include payslips, invoices, bank statements, contracts, provider statements, travel records, HMRC notices, payroll submissions, valuations or correspondence. Where an amount is apportioned, write down the method and retain the underlying total. If a correction is made, preserve the original figure and explain the reason, date and evidence for the replacement.

Before relying on the result, check the current official guidance for the same tax year and jurisdiction. Distinguish enacted law from a consultation, draft measure, announcement or future proposal, and record the effective date. Reconcile the final estimate to the relevant return, payroll record or HMRC account. A calculator or explanatory guide can support a decision, but it cannot replace the eligibility test or the official filing and payment process.

Evidence and decision checks

A reliable uk locum doctors vat 2026 27 review starts by fixing the tax year and the date on which the relevant event happened. Record the person's or business's status, the income or transaction category, the amount before tax, tax already withheld, and any election or claim being relied on. Do not combine a headline figure with a final liability: the result can change when another income source, a payment date, an ownership interest or a qualifying condition is added.

Keep the source documents behind every important input. Depending on the subject, that may include payslips, invoices, bank statements, contracts, provider statements, travel records, HMRC notices, payroll submissions, valuations or correspondence. Where an amount is apportioned, write down the method and retain the underlying total. If a correction is made, preserve the original figure and explain the reason, date and evidence for the replacement.

Before relying on the result, check the current official guidance for the same tax year and jurisdiction. Distinguish enacted law from a consultation, draft measure, announcement or future proposal, and record the effective date. Reconcile the final estimate to the relevant return, payroll record or HMRC account. A calculator or explanatory guide can support a decision, but it cannot replace the eligibility test or the official filing and payment process.

For related VAT processes, see the guide to UK VAT refunds for non-UK businesses and VAT groups and the guide to VAT for alternative education providers. The controlling sources remain HMRC RCB 6 and the current HMRC VAT notices.

Official sources

• HMRC — Revenue and Customs Brief 6 (2026): temporary medical staff
• HMRC — Health professionals and pharmaceutical products (VAT Notice 701/57)
• HMRC — How to correct VAT errors and make adjustments or claims (VAT Notice 700/45)
• HMRC — Partial exemption (VAT Notice 706)