Referees are not employees

A first-tier tribunal has ruled that National Group football referees should not be taxed as employees. The ruling, published May 2026, follows more than 10 years of legal arguments by HMRC that referees should be treated as payolled employees due to their season-long commitments to the PGMOL.

HMRC claimed that PGMOL owed £584,000 in unpaid tax in relation to matches between 2014 and 2016. The tribunal found that, even though the referees met two of the key tests HMRC relied on, the relationship between PGMOL and the referees lacked “the defining hallmarks of employment”. The referees concerned had other sources of income and were not economically dependent on PGMOL. They were able to accept or turn down engagements at will. The referees also followed the Football Association’s rules, rather than being managed or supervised by PGMOL.