As the UK tax year wraps up, it’s the perfect moment for employers to get ahead of their global mobility compliance, particularly around Short Term Business Visitors (STBVs) and Section 690 PAYE directions. With HMRC increasingly leveraging travel‑data matching, proactive compliance is no longer optional.
Below is a quick summary of the two upcoming deadlines for reference. Read on for more information.
| Reporting requirement | Deadline | When likely to apply |
| S690 application or renewal | From 6th April 2026
If you already have one for 25/26 you must renew |
Non-resident directors working in the UK for at least 1 day |
| Short term business reporting (annual reporting) | 31st May 2026
|
Overseas Group employees visiting the UK for short periods (typically required even for 1 working day in the UK) |
STBV Reporting Deadline: 31 May 2026
If you operate an Appendix 4 or Appendix 8 STBV Agreement, your 2025/26 STBV report is due by 31 May 2026.
This annual submission must accurately capture all qualifying overseas visitors. With HMRC now cross‑checking travel timelines more closely, omitted or misreported travellers may trigger PAYE exposure or follow‑up enquiries.
Section 690 Applications for 2026/27/: From 6 April 2026
A new Section 690 direction must be submitted each tax year.
Applications for 2026/27 can be made from 6 April 2026, helping employers operate PAYE only on UK workdays — critical for:
- non‑resident employees
- split‑year cases
- individuals eligible for Overseas Workday Relief
Submitting directions early ensures smoother payroll operations and reduces the risk of over‑deduction.
What Employers Should Be Doing Now
✔ Identify overseas employees working in the UK
Check you have relevant agreements in place with HMRC or risk unintended liabilities and penalties
✔ Be mindful of assignees/individuals on secondment to UK or overseas
Certificates often need renewing, for example, social security agreements with HMRC and any modified payroll agreements with HMRC require additional reporting outside of payroll
✔Review your 2025/26 STBV population
Confirm accurate tracking and ensure all visitors have been captured.
✔ Prepare your STBV report well before the deadline
Avoid late reporting risk and potential PAYE liabilities.
✔ Identify employees needing Section 690 relief (renewal) for 2026/27
Start gathering residence and work‑pattern information now.
✔ Don’t forget expenses and benefits provided to international employees/assignees etc
Often they are provided additional benefits/expenses, these could create additional tax and social security liabilities, or there could be potential to meet exemption criteria.
✔ Strengthen mobility governance and internal processes
HMRC’s enhanced access to travel data means robust systems matter more than ever.
What happens if I get it wrong?
It all depends on the facts, but to provide a simple example, failure to report correctly to HMRC could mean monthly fixed penalties of up to £400 per month plus tax geared penalties of up to 10% of the tax/NI due to HMRC.
Employees could also be left with personal income tax liabilities, administrative pain dealing with HMRC and overseas tax authorities and it could harm your employee retention.
How does BHP support employers managing cross-border employee matters?
Comprehensive Global Mobility Services
In addition to advising on the core risks detailed in this article, BHP’s team works with clients to ensure correct payroll setup and tax/social security withholding. We work alongside your payroll team, BHP payroll outsourcing or other advisors.
International Assignment Structuring
The BHP team helps employers plan and structure international assignments, implement secondment agreements alongside legal counsel, and assess tax residence risks. Our advice is underpinned by maximising available tax and social security reliefs and achieving desired commercial or people outcomes.
Governance and Coordination
BHP designs governance frameworks, provides guidance on travel tracking systems, and coordinates with overseas advisers and global networks.
End-to-End Client Support
Aligning HR, finance, payroll, and legal processes, BHP reduces risk, manages costs, and improves tax efficiency.
For more information, contact the global mobility team here.
This material is for informational purposes only and should not be relied upon as professional advice.
