Revenue disclosure window for misclassified workers

On 11 September 2025, Revenue announced a special opportunity for employers to regularise cases where workers were incorrectly classed as self-employed.

This follows the Supreme Court judgment in Revenue v Karshan (Midlands) Ltd, which introduced a new five-step framework for determining employment status. Many contractor and freelance arrangements may now fall within the scope of employment.

Employers who act within the window can settle liabilities for 2024 and 2025 without penalties or interest.

Who can disclose misclassified workers?

The facility is available to employers who:

• Incorrectly treated individuals as self-employed.
• Wish to correct PAYE, USC and PRSI liabilities for 2024 and 2025.
• Are not currently under a Revenue compliance intervention.

Conditions for disclosures on misclassified workers

To be accepted, a disclosure must be:

• Limited to the 2024 and 2025 tax years.
• Submitted via ROS using the dedicated facility.
• Paid in full (or supported by a Phased Payment Arrangement).
• Based on a genuine error — not careless or deliberate misclassification.
• Filed before Friday, 30 January 2026.

Why timely action matters

Employers who fail to disclose and are later found to have misclassified workers may face:

• Interest and penalties.
• Re-grossed PAYE liabilities, increasing costs substantially.
• Possible audits or compliance interventions.
• Reputational risks with staff, contractors, and stakeholders.

The disclosure facility is therefore a limited-time opportunity to resolve matters on more favourable terms.

Practical steps for employers

1. Review your workforce – reassess contractors and freelancers under the Karshan framework.
2. Calculate exposure – estimate PAYE, USC and PRSI liabilities for 2024 and 2025.
3. Prepare and submit – file through ROS with supporting calculations; request a phased arrangement if required.
4. Keep documentation – retain contracts and evidence of classification decisions.
5. Seek professional advice – expert support minimises error and ensures efficient compliance.

How Warren & Partners can assist

Our team advises employers on managing employment status risk and Revenue compliance. We can:

• Review contractor and freelance arrangements against the Karshan framework.
• Quantify potential PAYE, USC and PRSI liabilities.
• Prepare and submit disclosures on your behalf.
• Negotiate phased arrangements if needed.
• Provide ongoing support in any engagement with Revenue.

If you are concerned about employment status or wish to use the Revenue Disclosure 2025 facility, please contact our Revenue Engagement team.

Disclaimer: This article is for general information only and does not constitute professional advice.