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Godfrey Financial Advisors LLP

NI category letters: keep the evidence behind the code

In this hypothetical, a monthly-paid employee turns 21 on 10 November 2026. They are not an apprentice and earn £2,500 a month. In October, payroll uses National Insurance category M. In November it must use A, and the employer's contributions for that employee go from nothing to £312.45. The letter in the payroll record is a decision about who qualifies, and it needs evidence behind it. This covers the ordinary categories A, M, H and C in 2026 to 2027. Directors, mariners, deferment, veterans, Freeports, Investment Zones and multiple jobs have their own categories and rules.

HMRC CA38 states employers need the correct birth date and a written recognised apprenticeship agreement.
HMRC CA38 for 6 April 2026 to 5 April 2027, printed page 4, PDF page 6. The extract states the birth-date and written apprenticeship evidence needed for the under-25 employer NIC rate. HM Revenue & Customs. © Crown copyright. Contains public sector information licensed under the Open Government Licence v3.0. Cropped from the original.. Open Government Licence v3.0.

What the four letters mean

A applies to most employees. M is for employees under 21. H is for qualifying apprentices under 25. C is for employees over State Pension age within these ordinary categories. The last letter of a National Insurance number is not the category letter. Other categories exist, and an employee in one of them should not be moved to A by default.

M and H relieve the employer, not the employee. Under both, the employer rate is 0% up to the relevant upper secondary threshold, then 15%. The employee still pays ordinary NICs at 8% between the primary threshold and the upper earnings limit, then 2%. C works the other way: employee NICs stop and employer contributions continue.

For monthly pay in 2026 to 2027, HMRC publishes the secondary threshold as £417, the primary threshold as £1,048 and the upper limits as £4,189. Use those monthly figures as published, not annual amounts divided by 12.

Change the letter by payment date

HMRC's 2026 to 2027 further guide for employers says a payment made on or after the 21st birthday, or an apprentice's 25th birthday, uses the older-age category with the rates and limits in force on the payment date. A payment made before the birthday stays in the under-age category. If an employee qualifies both as under 21 and as an apprentice under 25, use the apprentice category.

For H, the apprenticeship must follow a recognised UK apprenticeship standard or framework, with a written agreement between the provider, apprentice and employer showing the start and expected completion dates. A job title with apprentice in it is not evidence. The CA38 tables also expect employers to hold birth-date and apprenticeship evidence.

The hypothetical in numbers

In this original hypothetical, the employee is not a director, has no special category and no other job, and is paid £2,500 of NIC earnings on 30 October and 30 November 2026. Employment Allowance, a separate employer-level offset, is left out.

Turning 21 does not change the employee's own NICs. It changes the employer's. If this employee were instead a qualifying apprentice under 25 with the required agreement, H could continue after the 21st birthday and the employer figure would stay at £0 at this pay level.

PaydayCategoryEmployee NICEmployer NIC
30 October 2026M(£2,500 - £1,048) × 8% = £116.16£0, pay below £4,189
30 November 2026A(£2,500 - £1,048) × 8% = £116.16(£2,500 - £417) × 15% = £312.45

State Pension age

State Pension age depends on the individual and is rising, so do not assume a fixed age or that retirement and State Pension age coincide. To move an employee to C, keep a passport or birth certificate, or an existing age-exception certificate. HMRC no longer issues new CA4140 certificates. Keep reporting year-to-date figures under the old category until the end of the tax year.

Sources and context, checked :

Before each payroll run

If a category turns out to be wrong, correct that employee's record. Do not move amounts between employees to make totals agree.

  • Check for 21st and 25th birthdays falling before the next payday
  • Check each employee's own State Pension age date
  • Hold the apprenticeship agreement, start date and expected completion date for anyone on H
  • Record the category chosen, the payday it takes effect and the evidence relied on
  • Keep year-to-date records under any previous category
  • Check for special categories before applying A or C

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