IR35 Status Dispute Letter: Free Template and What to Include
How to dispute an IR35 inside determination with your client — how to structure it, your rights.
A free fill-in template is at the end of this guide.
← All Letter Guides · Self Employed · Last updated 18 August 2026 · Published by UK Work Rights Ltd
This is free rights information, not legal advice. For advice specific to your situation, see our About page or contact Citizens Advice.
If you need to dispute an IR35 inside determination with your client, a written letter is the recommended first step — it creates a clear record and shows you're pursuing the matter formally. Below is what a strong ir35 status dispute letter should include.
What this letter needs to cover
- Formally dispute the status determination
- Set out why the contract should be outside IR35 based on substitution
- Control and mutuality of obligation tests
- Request a review of the determination
- Reference the Check Employment Status for Tax CEST tool if applicable
Why an inside IR35 determination might be wrong
IR35 status should reflect the genuine reality of how you work — the level of control the client has, whether you can send a substitute, and your level of financial risk. If your client has determined you're "inside IR35" without properly assessing these factors, or has applied a blanket policy without individual assessment, this can be legitimately challenged.
What to include before you send it
- A request for the specific reasoning behind the determination, if not already provided
- Your own assessment of key status factors — control, substitution rights, and financial risk
- Reference to your right to formally disagree under the client-led status disagreement process
- A request for the determination to be reviewed
Your right to a formal status disagreement process
Since the off-payroll working rules came into effect, clients are required to have a process allowing you to formally disagree with a status determination, and to respond with reasons within 45 days. If a client has no such process, or ignores your challenge, this is itself a compliance failure on their part.
Frequently Asked Questions
What happens if the client refuses to change the determination?
You can seek independent advice on your status, and in some circumstances this may need to be resolved through HMRC guidance or, in disputed cases, through tribunal.
Does an inside IR35 determination affect how I'm paid?
Yes — it generally means the fee-payer must deduct tax and National Insurance as if you were an employee for that engagement, which is exactly why getting the determination right matters financially.
Letter template
A letter to start from. Copy it, fill in the [square brackets] and change anything that does not fit your situation.
[Your Name / Your Limited Company Name] [Your Address] [Your Postcode] [Your Phone Number] [Your Email Address] [Name of Client Contact] [Client Company Name] [Client Address] [Client Postcode] [Date] Dear [Name of Client Contact], Subject: Disagreement with Status Determination Statement I disagree with the Status Determination Statement (SDS) issued on [Date], which says my engagement through [Your Limited Company Name] for [Role / Project] is inside the off-payroll working rules (IR35). I believe the engagement should be outside IR35: • Substitution: Clause [number] of the contract lets me send a suitable substitute, and in practice I can do so. • Control: I decide how, where and when the work is done, without day-to-day supervision. • Mutuality of obligation: You do not have to offer me more work, and my company does not have to accept it, beyond the current deliverables. Please tell me the reasons for your determination, if you have not already. [Optional: Please also show how HMRC's Check Employment Status for Tax (CEST) tool was used.] Under section 61T of the Income Tax (Earnings and Pensions) Act 2003, you must consider this disagreement and reply within 45 days, either with a new SDS or your reasons for keeping the original one. Yours sincerely, [Your Signature] [Your Printed Name]
General information, not legal advice. Change the letter to fit your situation. The copy button copies the letter to your device. We only count that a letter was copied – the text you copy is never sent or stored.
Related reading
Comments
Comments are loading…