The first Making Tax Digital quarterly update deadline of 7 August 2026 has passed, and the second falls on 7 November. Between those two dates sits a population of clients who missed the first one, a smaller population who have noticed, and a great deal of confident advice about what happens next.
Two rules govern the answer, and they pull in opposite directions. The data repairs itself. The penalty point does not.
Understanding how those two interact is the difference between a calm November and a set of client conversations nobody wants to have from August 2027, when the same missed deadline starts to earn points.
Key takeaways
- Quarterly updates are cumulative. HMRC: "Each time you send a quarterly update it will cover from the start of the tax year to the end of the update period, not just the previous three months."
- A missed first update is therefore carried by the second, which HMRC's developer guidance confirms "will satisfy the obligations for both Q1 and Q2".
- The same guidance adds the sting: "the customer may incur a penalty point for not submitting the first quarterly update on time."
- For this tax year the point is academic. HMRC: "There are no penalties for missing a quarterly update deadline for the 2026 to 2027 tax year."
- The waiver is written by year, not by taxpayer. Points apply "for tax years after 2026 to 2027", with a 4-point threshold carrying a £200 penalty, and each point removed "24 months after the missed deadline".
- Late payment carries no waiver in 2026-27 beyond the first-year 30-day window, and the rates step up for 2027-28.
The four dates, and what an update actually contains
The deadlines
For a taxpayer using MTD for Income Tax with a standard tax year, the quarterly update deadlines are 7 August, 7 November, 7 February and 7 May in the following tax year. Four dates, fixed, with the Self Assessment return and payment still due by 31 January after the end of the tax year.
What goes in one
An update is a summary of business and property income and expenses for the period. It is not a return, it carries no liability calculation, and nothing in it is a declaration of final figures. Adjustments, allowances and claims belong in the year-end process.
The rule that surprises people
HMRC states the mechanic plainly: each quarterly update covers from the start of the tax year to the end of the update period, rather than the three months just gone. Every submission restates the year to date.
✅ In practice: This is why a missed quarter does not leave a hole in the record. The next submission carries the whole year up to its own period end, including the months the missed update would have covered.
What actually happens when a client misses one
The scenario, from HMRC's own guidance
HMRC's developer guidance for MTD software works through precisely this case: "If a customer misses the deadline for the first quarterly update, such as by 7th August, they can still submit the second quarterly update by 7th November. The second update will satisfy the obligations for both Q1 and Q2."
That is the reassuring half, and it is worth saying clearly to a worried client. The obligation is met by the later submission.
The half that follows
The same passage continues: "However, the customer may incur a penalty point for not submitting the first quarterly update on time."
The data catches up. The compliance record does not. A point attaches to the missed deadline itself, and submitting later satisfies the obligation without erasing the lateness.
So what should a client do now
Send the outstanding update. Where the next deadline is close, the November submission will carry the earlier period, and there is no mechanism by which waiting improves the position. A client who has missed 7 August should be in the November cycle with the rest of the book, not treated as a special case.
Treat "the next update fixes it" as a statement about data completeness only. Repeating it to a client as though it also disposes of the compliance consequence sets up a difficult conversation in a later year, when the same sequence of events produces a point.
The grace year, read precisely
What HMRC has waived
For the current year HMRC's wording is short: "There are no penalties for missing a quarterly update deadline for the 2026 to 2027 tax year."
That is the whole of the concession, and it is generous. It is also narrower than the way it tends to be summarised in practice, because of what sits outside it.
What the grace does not touch
Three things continue to operate normally this year:
- The tax return deadline. The return itself remains subject to the points regime.
- Late payment penalties. Nothing in the quarterly update waiver reaches payment.
- Late payment interest. HMRC confirms "There are no changes to how late payment interest works", and charges it "From the first day your payment is late, until you pay in full".
The waiver is dated, not personal
The concession is written against a tax year. HMRC describes points as applying "for each quarterly update (for tax years after 2026 to 2027) or tax return deadline you miss". A taxpayer joining MTD later does not inherit a fresh grace year of their own on quarterly updates; the waiver belongs to 2026-27 and expires with it.
"The data catches up on its own. The point for missing the deadline stays where it landed."
What changes after 2026-27
The points ladder
From 2027-28 every missed quarterly update deadline earns a point. HMRC sets the threshold and the consequence in one line: "The penalty point threshold is 4 points. If you reach this, you'll get a: £200 penalty."
With four quarterly updates and one return in a year, a client who is habitually a fortnight late reaches the threshold inside twelve months.
How long a point lasts
Below the threshold, points expire on their own: "If you're below the 4-point threshold, we'll automatically remove each point 24 months after the missed deadline." A single slip therefore ages out. At the threshold the 24-month clock stops applying: HMRC removes the points only after you "send your quarterly updates and submit your tax return on time for 12 months" and "send any outstanding quarterly updates and submit any outstanding tax returns for the previous 24 months". A client at four points who is told they will drop off in two years has been misadvised.
Late payment, by year
The first-year concession on payment
HMRC frames one relief by the taxpayer's own position rather than by the calendar: "In your first year of new penalties, you have 30 days from the payment due date", and "After your first year, this reduces to 15 days."
Key date: 7 November 2026, the second quarterly update deadline of the 2026-27 tax year. For clients who missed 7 August, this is the submission that carries both periods.
A practical sequence for the autumn
The work here is list-building rather than technical, and it is best done before the November deadline rather than after it.
- Identify the missed. Pull every MTD-mandated client and check which have no Q1 submission recorded. The client-facing online account lists a taxpayer's own position; agent visibility depends on authorisation being correctly in place.
- Confirm authorisation before you diagnose anything. A client who appears to have missed an update sometimes turns out to be a client the practice cannot see. Check the agent authorisation first, so the list reflects filing behaviour rather than access gaps.
- Get the whole book onto the rhythm. Four dates, booked as recurring work, with the bookkeeping cut-off a fortnight earlier. The habit is what survives into the years when misses carry points.
- Separate the payment conversation. Clients who have heard that there are no penalties this year need to understand that the waiver covers quarterly updates and stops there.
- Record what you told them. A dated file note of the advice given on the grace year is cheap now and valuable if a later dispute turns on what the client understood.
Where a question turns on the precise wording of the penalty rules rather than on the process, it is worth reading the provision rather than a summary of it. A research tool that returns cited answers grounded in UK legislation and HMRC guidance shortens that, and our sources and update policy sets out how currency is maintained when guidance pages change mid-year, as these have repeatedly. You can create a free account and test it against your own MTD questions.
Conclusion
The two rules governing a missed quarterly update are simple once separated. Cumulative submission means the record repairs itself at the next deadline, so no client is left with a permanent hole in their year. The penalty regime attaches to the deadline that was missed, so the repair settles the data and leaves the compliance position where it was.
For 2026-27 that second half costs nothing, because HMRC has waived penalties for missed quarterly update deadlines this year. From 2027-28 it costs a point, four points cost £200, and below the threshold each point sits on the record for 24 months; at the threshold they clear only after twelve months of on-time submissions.
The practices that will find August 2027 uneventful are the ones using this year to build the four-date rhythm while the misses are free. A quarterly update habit formed under a waiver is the only part of this that carries forward.
For the wider picture on selecting research tools that keep pace with guidance changing this often, see our guide to choosing AI tax research software in the UK, and the limitations and responsible use page for where professional judgement stays with the adviser. Firms rolling this out across several seats can book a call.
Frequently asked questions
What happens if I miss an MTD quarterly update deadline?
The obligation is met by your next quarterly update, because each update covers from the start of the tax year to the end of its own period rather than the previous three months. HMRC's developer guidance confirms that a second update "will satisfy the obligations for both Q1 and Q2", while noting that a penalty point may still be incurred for the deadline that was missed.
Are there penalties for missing quarterly updates in 2026-27?
No. HMRC's guidance states that "There are no penalties for missing a quarterly update deadline for the 2026 to 2027 tax year." The waiver covers quarterly updates only. The tax return deadline, late payment penalties and late payment interest all continue to operate normally during the same year.
How many penalty points trigger a fine under MTD?
The penalty point threshold is four points, and reaching it produces a £200 penalty. Points apply to missed quarterly update deadlines for tax years after 2026 to 2027, and to missed tax return deadlines. Below the threshold, each point is automatically removed 24 months after the missed deadline. At or above it, the points are removed only after twelve months of on-time submissions and once every outstanding submission for the previous 24 months has been sent.
Are MTD quarterly updates cumulative?
Yes. HMRC states that "Each time you send a quarterly update it will cover from the start of the tax year to the end of the update period, not just the previous three months." Each submission restates the year to date, which is why a later update carries the periods covered by any earlier one that was missed.
What are the MTD quarterly update deadlines?
For a standard tax year the four deadlines are 7 August, 7 November, 7 February and 7 May in the following tax year. The Self Assessment return and the balancing payment remain due by 31 January after the end of the tax year.
Do late payment penalties change in 2027-28?
Yes. For 2026-27 the rate charged is 3% of the tax owed at day 15 and a further 3% at day 30, while for 2027-28 both steps rise to 4%. In a taxpayer's first year of the new penalties HMRC charges nothing at day 15, because the 30-day window below applies. From day 31 an annual rate of 10% on the outstanding amount is charged daily in both years. A first-year concession gives 30 days from the payment due date before penalties apply, reducing to 15 days after that first year.

