HMRC: image rights payments to be taxed as employment income from 6 April 2028

HM Revenue & Customs has published a tax information and impact note on the tax treatment of image rights payments connected to employment. The document was published on 28 October 2026, and the page was updated on 6 November 2026.

What is changing

The government wants to make clear that payments for image rights connected to employment are taxable as employment income, in the same way as wages. This also applies to National Insurance contributions. According to HMRC, the change is meant to clarify the law in an area where a small number of employers have treated such earnings inconsistently for Income Tax and National Insurance purposes.

Image rights are not defined in UK law. HMRC describes them broadly as the legal rights associated with the use of a person's image, likeness or persona. Current law makes no explicit reference to them, which creates uncertainty over whether arrangements are connected to the employment.

Who is affected

The change will affect employees who receive such payments in connection with their employment, whether paid directly to them or through a third party. It will also affect the employers who make the payments. The note says it is likely to mainly affect the professional sports sector.

Entirely separate arrangements with a third party that are not related to employment are not covered.

Timing and how it will be introduced

The measure was announced at Budget 2025 and was due to take effect from 6 April 2027. The government has decided to delay it by a year, to 6 April 2028, to give employers and employees more time to adjust.

Primary legislation will clarify that these payments are employment income. It will also introduce a power to make regulations for deemed employment relationships. Separate regulations, using existing powers, will make the payments subject to Class 1 National Insurance contributions, both primary (employee) and secondary (employer).

Impact on the Exchequer

HMRC estimates the Exchequer impact at £10 million in the 2026 to 2027 tax year and £10 million in 2027 to 2028. In the following years it is £40 million (2028 to 2029) and £45 million a year from 2029 to 2030 to 2031 to 2032. The figures come from the overall table of Budget policy decisions on measures to close the tax gap.

What this means for you

The change affects a narrow group: people who receive separate payments for the use of their image as part of their employment, mainly professional sportspeople, and their employers. Most employees in the UK are not affected. Anyone with such arrangements in their contract should check how they are taxed with a tax adviser.