Registering with HMRC: the 5 October deadline that catches new private practices

If you qualified this year and started taking private clients, or added a couple of paying clients alongside an employed post, there is a date in early October you may not have heard of. Telling HMRC you exist has its own deadline, separate from the tax return itself, and it falls well before the January date everyone knows about.

For the tax year that ended on 5 April 2026, the deadline to register for Self Assessment is 5 October 2026. If that applies to you, it is about six weeks away.

This is general information, not tax advice. Whether you need to register, and when your trading actually began, turn on your own circumstances, and those are questions for an accountant rather than a blog post. What this piece can do is put the deadline on your radar and explain the part that catches therapists out most often.

What the deadline is, and what it is not

Two separate obligations get muddled here.

Registering is telling HMRC you have income to declare. For money earned in the 2025/26 tax year (6 April 2025 to 5 April 2026), that deadline is 5 October 2026.

Filing and paying come later. The online return for the same year is due by 31 January 2027, with the tax.

The gap between them matters, because registration is not instant. You register through a Government Gateway account, and HMRC then issues a Unique Taxpayer Reference, the UTR, which arrives by post. Published guidance puts that at roughly ten working days, longer if your address is outside the UK. You cannot file without it. Leaving registration until late January is how people end up filing late for reasons that have nothing to do with their bookkeeping.

The £1,000 figure, and the trap inside it

Broadly, HMRC's published position is that gross trading income of £1,000 or less in a tax year may not require registration at all, under what is called the trading allowance. Above that, the obligation applies.

The word doing the work is gross. That is your total fee income before you take off room hire, supervision, insurance, membership, training or software. Not your profit, and not what survived in your current account after costs.

That distinction catches therapists repeatedly, and it is the same trap as the qualifying-income threshold in Making Tax Digital. Two private clients a week at £60, started halfway through the year, is somewhere around £3,000 gross. The profit left after costs might be a few hundred pounds. It is the £3,000 that counts here.

The allowance is also generally looked at across your trading income as a whole rather than per source, so a small private caseload plus any other freelance work gets considered together. If you are anywhere near the line, that deserves an accountant's eye rather than a mental estimate.

Who this actually catches

Three situations come up repeatedly.

You qualified partway through the year and saw a few clients. Even a handful of sessions counts. The obligation attaches to having the income, not to the practice feeling established yet.

You have an employed post alongside the private work. This is the big one. Plenty of therapists hold an NHS, agency, charity or education post and see two or three private clients around it, then assume PAYE covers everything. PAYE cannot account for income your employer never saw. The registration rules apply whether or not there is also a salary.

You started trading earlier than you think. Trading tends to begin when you start working for clients, not when you registered a business name or finally built the website. If the first paid session fell in that tax year, that is the year in question.

If you have missed it, or think you might have

Do not panic, and do not go quiet.

Missing the registration deadline can bring what HMRC calls a failure to notify penalty. As published, it is calculated from the tax that went undeclared as a result, so a small liability tends to mean a small penalty, and guidance indicates the penalty can fall to nothing where the tax is paid in full by the 31 January deadline. Being late is treated very differently from deliberately hiding income.

Worth knowing in advance, though: not having known about the rule is not generally accepted as a reasonable excuse.

If you think you have missed it, talk to an accountant this week rather than next month. It is a routine problem with a routine fix, and the fix costs less the earlier it starts.

What it changes about how the practice runs

Registering itself is a short administrative job. What has an ongoing cost is what it commits you to: a return every year, built from a record of what you invoiced, what was paid, and when.

That record is the thing worth getting right early, and not only for tax. It is what an accountant asks for first, and it is what the quarterly reporting in the admin checklist for a new practice eventually draws on as the thresholds come down. Reconstructing a year from a bank statement and memory in January is a genuinely miserable weekend. Capturing it as you go is close to free.

What software can and cannot do about this

Faresay does not register you with HMRC, does not file anything on your behalf, and is not MTD-compatible filing software. If a practice tool implies it handles your tax, ask it to say exactly what it means.

What software affects is the layer underneath: every session and payment recorded as it happens, and a CSV export of your payments whenever you want one, for your accountant, your own records, or to take with you if you leave. That is the raw material a return gets built from. It is not a substitute for the registration or for the accountant.

Working out whether it applies to you

1. Work out your gross self-employed income for the year to 5 April 2026, before expenses.
2. Check the current position on GOV.UK, which publishes the registration rules and the deadline, rather than trusting a summary like this one.
3. Ask an accountant if you are near the line, or if you are unsure when your trading began. The fee is a deductible business expense.
4. Register early rather than on 4 October, so the UTR arrives with room to spare.
5. Record income as it happens, so January is a reading exercise rather than an archaeological one.

Why it slips past people

None of this is hard. It is just quiet. No letter arrives to warn you the deadline is coming, and the people it catches hardest are the ones who started small, felt it was barely a business yet, and assumed something else was handling it.

If you saw a paying client between April 2025 and April 2026, spend ten minutes this week working out whether 5 October applies to you. It is a better use of ten minutes than the alternative.

This article describes HMRC rules as they stood in August 2026 and is provided for general information. It is not tax, accounting or financial advice, and it does not take account of your circumstances. Check the current position on GOV.UK and take advice from your accountant before acting. Deadlines, thresholds and penalty rules have changed before and may change again.

Faresay is practice management software for UK therapists. See how it works, or compare it with the alternatives.