Contract project managers (IT, programme, transformation and PMO leads) face one of the higher IR35 risk profiles in contracting. Client-side direction over priorities, integration into governance structures and long programme engagements all create exposure. Getting the working practice right matters as much as the contract.
Project managers who report into a client's Programme Management Office, attend client steering committees and are managed by a client SRO (Senior Responsible Owner) are operating within the client's control framework. The control test is almost always triggered in these arrangements. Whether other factors (substitution, MOO, financial risk) offset this requires careful analysis.
Multi-year transformation programmes create a pattern of mutual obligation that HMRC examines carefully. If your role as a programme manager on a client's enterprise system implementation has been extended repeatedly and is effectively filling a permanent programme function, the MOO argument is harder to defend.
A significant proportion of contract project manager work is in the public sector (central government, NHS, local authorities), where client-side IR35 determination has applied since April 2017. Many programme managers received inside determinations at that point and have been on inside IR35 terms since. The question of whether to challenge those determinations or restructure the engagement deserves proper analysis.
We look at both what the contract says and how the role actually operates. For project managers, the practical reality of governance arrangements, reporting lines and how priorities are set is what drives the IR35 analysis.
If you are inside IR35, there are still planning opportunities, including pension contributions from the PSC, income timing, and operating alongside other outside IR35 contracts. We make sure the structure is as efficient as possible even where the status cannot be changed.
Where a client's status determination appears incorrect, we support the formal challenge process, reviewing the SDS, preparing the representation, and managing the 45-day response window.
Book a free call. We will talk through your IR35 position, your structure and whether there is anything worth changing. No hard sell, no obligation.