re Your Workers Employed or Self-Employed? What the PGMOL Case Tells UK Businesses
Employment status has always been one of the trickier areas of UK tax law, and a landmark tribunal decision handed down on 1 May 2026 has put it firmly back in the spotlight. The case is Professional Game Match Officials Ltd v HMRC [2026] UKFTT 654 (TC), and while it involves football referees, the lessons it contains apply to businesses of all kinds.
The Background
Professional Game Match Officials Ltd (PGMOL) is the organisation that provides referees for professional football matches in England. HMRC argued that match officials should be treated as employees, meaning PAYE and National Insurance contributions should have been applied to the match fees paid to them. With over £583,000 at stake, PGMOL disagreed and took the matter to tribunal.
This was not a straightforward case. It had already travelled through the Upper Tribunal, the Court of Appeal and all the way to the Supreme Court before landing back at the First Tier Tribunal for a final determination. The Supreme Court had confirmed that when a referee accepted a match appointment, there was sufficient mutuality of obligation and a framework of control in place. However, it sent the case back to the FTT to look at the overall picture of the relationship and make a final call on employment status.
What the Tribunal Decided
The FTT took a step back and considered the relationship as a whole. Its key findings were:
- PGMOL was not required to offer matches, and referees were not required to accept them
- Referees could decline appointments or withdraw without penalty
- Each match appointment was a short, discrete engagement with no ongoing commitment
- Most referees carried out their refereeing work alongside other full-time employment
Taking all of this into account, the Tribunal concluded that the relationship simply did not have the hallmarks of employment. The referees were self-employed, and PGMOL was not required to operate PAYE or pay employer National Insurance on the fees it paid them.
Why Does This Matter for Your Business?
The PGMOL case is a reminder that employment status is never determined by a single factor. It does not come down to who provides the equipment, how often someone works for you, or whether there is a written contract calling someone self-employed. What matters is the overall picture of the working relationship, assessed across multiple factors at once.
Getting this wrong can be costly. If HMRC concludes that someone you treat as self-employed should actually be classified as an employee, you could face a significant bill for unpaid PAYE, National Insurance and penalties, potentially going back several years.
If you engage contractors, freelancers or other flexible workers and you are not completely confident about their employment status, it is well worth having that conversation sooner rather than later.
At A&C Chartered Accountants, we help businesses across Manchester review their worker arrangements and make sure they are on solid ground with HMRC. We would be happy to take a look at your situation and give you a clear, practical view.
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This article is based on publicly available tribunal decisions and HMRC guidance current as of June 2026. Tax rules can change. Please speak to a qualified accountant before making decisions based on this content.