The SA109 deferral is the key date for most non-residents
Non-resident landlords normally file the SA109 residence pages every year alongside the property pages, and HMRC has confirmed that everyone who included the SA109 on their 2024/25 return is automatically exempt from MTD until April 2027, regardless of income. Most established non-resident landlords are therefore not in the April 2026 wave even where gross rents are well over £50,000. It is a postponement, not an escape: from 6 April 2027 the normal thresholds take over, so an SA109 filer with qualifying income over £30,000 on the 2025/26 return should expect to start then. Our guide to Making Tax Digital for non-resident landlords covers the full timetable, software options and exemptions.
The common traps: gross income, joint property and new leavers
Qualifying income is gross rent plus self-employment turnover before expenses, so a landlord with £52,000 of rent and £20,000 of costs is in scope despite a £32,000 profit. For jointly owned property only your share counts, and for non-residents only income declared on a UK return counts, so foreign income outside the UK system is ignored. Having 20% deducted at source under the Non-Resident Landlord Scheme changes nothing: the scheme governs collection, not reporting. New leavers must apply for the deferral by phone or in writing, and the normal rules apply to them until HMRC grants it.
What to do now
Pull your 2024/25 return and add up gross rents plus any self-employment turnover to find your start date, then check whether the SA109 was included. If you are leaving the UK this year, apply for the deferral promptly rather than assuming you have it. Once your start date is fixed, choose MTD-compatible software, or an agent who runs it for you, and diarise the quarterly deadlines and the 31 January return. Nothing is paid quarterly, and HMRC has confirmed no penalties for late quarterly updates in the 2026/27 year, though the £200 penalty-points system applies thereafter.