How long does a CIS refund take when HMRC is checking it?

Once HMRC opens a check on a CIS refund, there is no fixed statutory turnaround; it typically runs several weeks to a few months, longer for complex reviews. HMRC will request records under Schedule 36 Finance Act 2008 first, and the refund is normally held back until the check concludes.

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Do this first

Reconcile your deduction statements against the refund claimed.

If the reply date on your letter is within 14 days, call 020 3441 1258 rather than waiting, or check the reply to an enquiry you have already sent.

Key facts

Statutory basis
Chapter 3 Part 3 Finance Act 2004 and the Income Tax (Construction Industry Scheme) Regulations 2005
Applies to
Limited company contractors claiming repayment of CIS deductions suffered as a subcontractor
Typical timescale
No set legal deadline once a check opens; delays of several weeks to a few months are common
Information requests
HMRC can demand supporting records under Schedule 36 Finance Act 2008, usually with usually at least 30 days to produce the documents listed
Appeal route
You can complain about unreasonable delay, or appeal a formal decision within 30 days from the date of the decision or assessment

The short answer, explained

Most CIS refunds process quickly once the company tax return or Employer Payment Summary reconciliation is submitted. Once HMRC flags the claim for a check, that changes.

There is no statutory deadline forcing HMRC to complete a CIS compliance review by a set date. In practice, straightforward checks resolve in weeks; those involving employment status or subcontractor verification issues can take considerably longer.

The refund is generally held until HMRC is satisfied the deductions claimed match the CIS returns and payment records it holds.

The rule behind it

The Construction Industry Scheme is set out in Chapter 3 Part 3 Finance Act 2004 (opens in a new tab), which requires contractors to deduct tax from payments to subcontractors and pass it to HMRC.

The Income Tax (Construction Industry Scheme) Regulations 2005 set out the mechanics of monthly returns, deductions statements, and how a subcontractor company reclaims deductions suffered against its own liabilities.

Where HMRC has doubts about the figures, it uses its Schedule 36 Finance Act 2008 powers to request contracts, invoices, bank statements, and deduction statements before releasing a refund.

There is no equivalent to the VAT repayment supplement regime for CIS refunds, so there is less financial pressure on HMRC to move quickly, beyond the general duty to act within a reasonable time.

What this means for a limited company director

Keep every deduction statement from contractors you worked for during the year; gaps or mismatches are the most common reason a refund is queried.

Respond fully and promptly to any Schedule 36 notice. Partial or late responses extend the review and can trigger penalties in their own right.

If cash flow is tight while waiting, consider whether a time to pay arrangement or short-term facility is more realistic than assuming the refund will land on a normal timescale.

What this costs you

The direct cost is usually cash flow: a delayed refund ties up working capital your company may be relying on.

If the review escalates into a wider employment status or CIS compliance review, professional fees to manage the response can add up. Growth plan clients have free tax investigation insurance included to cover exactly this kind of enquiry — details at /fees.

Poor record-keeping that prolongs the check indirectly costs you in both delay and adviser time spent reconstructing missing paperwork.

Common mistakes to avoid

Do not chase HMRC repeatedly without providing the requested evidence first; incomplete responses are the main cause of delay.

Do not assume silence means approval; ask for a written update if you have heard nothing after a reasonable period.

Do not submit a refund claim without reconciling it against your own CIS deduction statements first; mismatches are what trigger checks in the first place.

What to do next

  1. Reconcile your deduction statements against the refund claimed.
  2. Respond fully to any Schedule 36 information request.
  3. Chase HMRC in writing if there is no update after a reasonable period.
  4. Consider a time to pay arrangement if cash flow is affected.
  5. Get specialist support if the check widens into a full review.

Where we can help

Sources

About the author

Waqas Sagar ACA FCCA FMAAT, Managing Director. 18+ years advising UK directors on HMRC enquiries, supported by a team with over 100 years' combined experience.

Reviewed: 16 September 2026 · Next review: 16 March 2027

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