The courts just underlined the importance of Ready Mixed Concrete Stage 3. So even if both Mutuality and Control go against you as a contractor, there’s still no automatic presumption of employment.
The May 1st 2026 decision from the First-tier Tribunal (FTT) in Professional Game Match Officials Ltd v HMRC is a significant status decision, but it is not applicable to all. The PGMOL case is much narrower than that.
PGMOL V HMRC: what’s the real importance?
The real importance of the decision in favour of PGMOL is that it shows what happens after mutuality of obligation and the framework of control have been established.
HMRC won those gateway points in the Supreme Court.
But on remission, PGMOL still won because the FTT held that the individual match engagements were contracts for services, not contracts of employment.
That makes PGMOL’s win important for IR35 and off-payroll working, but it needs handling careful, writes employment status expert Rebecca Seeley Harris, a tax lawyer and the founder of Re Legal Consulting.
What is the history of PGMOL?
The litigation history of PGMOL is now well known. The original FTT found that the National Group referees contracted with PGMOL, but that the individual match engagements were not employment contracts. The Upper Tribunal upheld the result on mutuality. The Court of Appeal disagreed, holding that both mutuality and control were present. The Supreme Court then confirmed that each accepted match appointment involved the...
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