Association of Practising Accountants

New UK-India National Insurance Treaty Now in Force: What Employers Must Know

Regulation

The UK-India National Insurance Double Contributions Convention entered into force on 15 July 2026. Accountants advising employers with India operations must understand the new certificate of coverage process and compliance requirements.

The UK and India have established a new National Insurance Double Contributions Convention (DCC), which formally entered into force on 15 July 2026. The agreement directly affects employees and their employers moving between the two countries.

For accountants advising multinational businesses and employers with staff working in India, understanding this treaty's mechanics is now essential.

HMRC has published technical guidance in the National Insurance manual at NIM33250, setting out how the DCC provisions operate—guidance that employers should review before any employee moves between the UK and India.

What the Convention Achieves

The primary purpose of a Double Contributions Convention is to prevent workers from being liable for National Insurance contributions in both countries simultaneously. Without this protection, UK employees sent to work in India would face a punitive double burden: they would continue to pay UK National Insurance whilst simultaneously becoming subject to Indian social security contributions. The new DCC eliminates this overlap for covered workers.

Employees who will remain liable to pay UK National Insurance contributions whilst working in India, or their employers, can now apply to HMRC for certificates of coverage using the online CA9107 form. These certificates confirm that an employee will continue to pay National Insurance contributions in the UK and will not be liable to pay social security contributions in India.

Practical Implications for Accountants and Employers

The certificate of coverage is the critical document. Once issued, it acts as proof of the employee's social security status and protects them from dual liability. Employers and advisers should ensure that:

  1. Early application: Before an employee is assigned to India, the application for a certificate should be made. Retroactive applications may face delays.

  2. Record-keeping: The certificate should be retained and provided to both the UK employer and the Indian employer. It may be requested during audits or compliance checks in either jurisdiction.

  3. Scope clarification: The DCC applies to employees covered under its terms; self-employed individuals and some other categories may have different rules. Professional advice is recommended for non-standard arrangements.

  4. Coordination with payroll systems: UK payroll teams must continue to operate PAYE and National Insurance deductions as normal, even whilst the employee works abroad. The certificate of coverage does not suspend UK contributions—it simply prevents double contributions.

Recent Employer Engagement

In June 2026, HMRC advised that from August 2026 it would begin contacting around one million eligible individuals directly about the provisions of the convention. This mass contact campaign signals HMRC's intent to encourage awareness and uptake of the scheme. Employers may therefore expect increased enquiries from staff in India or planning secondments.

What's Next

The entry into force of this convention is part of a broader UK strategy to facilitate cross-border employment and investment. As business mobility between the UK and major markets like India increases, practitioners should expect similar treaties with other jurisdictions to be negotiated and implemented. Staying current with HMRC's technical guidance and maintaining awareness of employees' social security status in overseas jurisdictions is now a core compliance responsibility.

Employers and accountants should review HMRC's technical guidance at NIM33250 and consider whether any current or planned India assignments require a certificate of coverage application. Early and proactive engagement will reduce compliance risk and simplify payroll administration.