MTD for Income Tax exemptions: check the route and the expiry date
In a hypothetical review of the 2026 to 2027 tax year, two landlords each met the ordinary entry test for April 2026. The first included the SA109 residence pages in their 2024 to 2025 Self Assessment return. The second did not, but reasonably expects to need SA109 for 2025 to 2026. Under HMRC's guidance the first is automatically exempt for 2026 to 2027, and that exemption ends in April 2027. The second has a reason to apply, but no exemption until HMRC accepts an application.
Selected routes and how they arise
HMRC divides exemptions into those that apply automatically, with no application, and those that need one. Some automatic exemptions are permanent unless circumstances change; others are temporary. The table shows selected routes only. HMRC's page has the full list and the exact category names.
| Route | Basis | Application needed? | Duration |
|---|---|---|---|
| SA109, SA107 trust or estate income, qualifying care relief, or averaging relief on SA103 | Included in the 2024 to 2025 return | No | 2026 to 2027; ends April 2027 |
| The same pages or claims, newly expected | Absent from the 2024 to 2025 return, but reasonably expected in the 2025 to 2026 or 2026 to 2027 return | Yes for this route | HMRC's decision letter states it; check it against the route's published end date |
| Averaging relief on SA104 | Claimed in 2024 to 2025, or reasonably expected in 2025 to 2026 or 2026 to 2027 | Yes, even if claimed for 2024 to 2025 | HMRC's decision letter states it; check it against the route's published end date |
| Ministers using SA102M, or claims for Married Couple's Allowance (born before 6 April 1935) or Blind Person's Allowance | Included in the 2024 to 2025 return | No | Beyond April 2027; no start date announced |
| Digital exclusion | Personal circumstances make compatible-software use unreasonable; HMRC assesses the application | Yes | Stated in HMRC's decision letter |
Sources and context, checked :
The SA109 case: an end date, then the normal test
Other automatic routes include having no National Insurance number before the tax year starts, and roles such as trusts filing SA900, non-resident companies filing SA700 and personal representatives. A personal representative's own income still needs its own check.
For the first landlord, HMRC says the SA109 exemption ends in April 2027, after which the ordinary entry test applies. For April 2027 that test looks at qualifying income over £30,000 in 2025 to 2026. Before next April, check the 2025 to 2026 figures rather than assume the exemption carries on.
For the second landlord, record the application as pending until HMRC replies.
Sources and context, checked :
Digital exclusion is HMRC's decision
HMRC considers digital exclusion case by case. Reasons can include age, health, disability, location or qualifying religious beliefs; unfamiliarity, extra time or cost alone is insufficient. HMRC's guidance sets out the detailed conditions. Applications are open for April 2026 and April 2027 entrants. April 2028 entrants can apply from summer 2027.
Apply by phone or letter, giving identity details, the grounds and supporting information, including how returns are filed now, any agent's role and the support needed. If an agent can do the digital work, the requirements may be met without an exemption. HMRC aims to reply within 28 calendar days, which is a target rather than a promise. The decision letter states the exemption's type and duration. Someone already signed up whose circumstances change keeps using MTD while waiting. A refusal letter explains the appeal route; the published period is 30 days from the letter's date.
Sources and context, checked :
What an exemption does not change
An MTD exemption is not an exemption from Self Assessment. Normal returns and recordkeeping continue. Being older, owning rental property abroad, having filed on paper or using an agent does not on its own make someone exempt.
Keep a one-page exemption note
We suggest a short note for each taxpayer recording:
- The exact HMRC category name
- The return page, claim or circumstance that supports it
- Whether the route is automatic or by application
- The tax years covered
- The evidence held, or the date of HMRC's decision letter
- A review date before the exemption expires
Start with last year's return
For an application, note what was sent, when, and HMRC's reply, and mark the person exempt only once the letter arrives. The quickest first step is to open the 2024 to 2025 return and list which pages and claims it actually contains.