A freelance GP can complete an NHS session, receive the correct fee and still lose the opportunity to pension that work if the pension administration is not completed correctly and on time.
That is why GP Locum Forms A and B matter.
For qualifying freelance GP locum work, Form A records the individual engagement and pensionable pay, while Form B brings the pensionable income and contributions together as part of the monthly NHS pension process.
For 2026/27, some of the most important rules are:
- 90% of the basic locum fee is pensionable.
- The employer contribution and administration amount shown on Form A is 14.38% of pensionable pay.
- Employee contribution rates range from 5.2% to 12.5%, depending on the applicable annualised GP pensionable income.
- Freelance GP locum work that falls outside the 10-week pensioning window cannot normally be pensioned through the standard Forms A and B process.
- Income invoiced through a limited company cannot be declared using GP Locum Form A.
- Self-employed out-of-hours and relevant ICB work can follow a different pension process.
- GPs combining salaried, partnership, Solo or freelance locum roles may have additional pension reconciliation requirements.
For locum GPs with several income sources, pension records and tax obligations, our specialist NHS Pension Accountants can help reconcile the pension, income and tax position together.
What Are GP Locum Forms A and B?
GP Locum Forms A and B are used to administer qualifying pensionable freelance GP locum work within the NHS Pension Scheme.
Although the two forms are connected, they perform different functions.
What Is GP Locum Form A?
GP Locum Form A records an individual qualifying freelance GP locum engagement.
It normally records information such as:
- the GP locum;
- the practice or relevant commissioning body;
- the actual dates worked;
- the basic locum fee;
- the 90% pensionable amount;
- the employer pension contribution.
In England, Form A can be submitted through PCSE Online for approval by the relevant practice.
What Is GP Locum Form B?
GP Locum Form B is the monthly summary of pensionable freelance GP locum income and associated pension contributions.
It brings together information relating to the underlying Forms A and helps determine the employee and employer contributions associated with that month’s pensionable locum work.
It also contains cumulative pensionable-income information that is relevant when monitoring the GP’s contribution tier.
GP Locum Form A vs Form B
| Feature | GP Locum Form A | GP Locum Form B |
|---|---|---|
| Main purpose | Records the individual locum engagement | Monthly pension contribution summary |
| Actual dates worked | Yes | Based on underlying A forms |
| Basic locum fee | Yes | Summarised indirectly |
| 90% pensionable pay | Calculated | Brought into monthly total |
| Practice involvement | Practice approves/confirms | Mainly locum administration |
| Employer contribution | Calculated | Included in monthly summary |
| Employee contribution | Not the main calculation | Calculated/summarised |
| Contribution tier | Not primary purpose | Relevant |
| Cumulative pensionable income | No | Yes |
| Payment | Supports calculation | Contributions are paid following submission |
The easiest way to think about the process is:
Form A identifies and verifies the work. Form B brings the pensionable work together for the monthly contribution process.
The GP Locum NHS Pension 10-Week Rule
The GP locum pension 10-week rule is one of the most important parts of the entire process.
NHS pension rules do not allow a freelance GP locum simply to leave all their pension administration until the end of the tax year.
Where qualifying locum work falls outside the permitted 10-week window, the work cannot normally be pensioned retrospectively through the standard locum process.
This makes the date the work was performed critically important.
Example: Late Practice Payment
Assume Dr A performs a locum session on:
15 June 2026
but the practice does not pay the invoice until:
20 August 2026
The GP should not assume that the 10-week period begins when the invoice is finally paid.
The pension timetable relates to the underlying locum work.
This is why both practices and locums need to process pension paperwork promptly.
Waiting for the tax-return deadline or year-end accounts before checking Forms A and B can therefore be a serious mistake.
The 10-Week Rule and the Monthly Contribution Deadline Are Different
Locum GPs should understand that there are two related but different time limits.
| Requirement | Timing |
|---|---|
| Pensionability of underlying freelance locum work | Keep the work within the 10-week pensioning window |
| Monthly contribution process | Employee and employer contributions should be paid no later than the seventh day of the following month |
The 10-week rule should therefore be treated as a backstop, not as the normal target for administration.
A better routine is to process pensionable locum work monthly.
If you wait until the work is nearly ten weeks old before beginning the process, a delayed practice approval or administrative problem can put the pensionability of that work at risk.
Who Can Use GP Locum Forms A and B?
Forms A and B are designed for qualifying freelance GP locum work.
Relevant work can include a GP working as an individual and:
- deputising for an absent GP;
- temporarily assisting a GP practice;
- carrying out qualifying work that falls within the locum pension rules;
- undertaking certain appraisal work, depending on the GP’s wider practitioner status.
The key point is that merely being described as a “locum doctor” does not automatically make every engagement eligible for the freelance locum pension process.
The substance and duration of the arrangement matter.
Who Should Not Use GP Locum Forms A and B?
Several types of work should not be put through the standard freelance GP Locum A and B process.
1. Locum Income Invoiced Through a Limited Company
If the invoice for the work is issued by the GP’s limited company, the income cannot be declared on GP Locum Form A.
This is an important issue for doctors deciding whether to operate personally or through a company.
A limited-company structure may have tax, commercial and administrative implications, but the NHS pension consequences also need to be considered.
Doctors considering different working structures may find our guide to IR35 and healthcare workers useful alongside advice from our specialist locum doctor accountants.
2. GP Provider Locuming in Their Own Practice
A GP provider cannot normally pension income as a freelance GP locum in their own surgery using Forms A and B.
That income falls within the appropriate practitioner pension framework instead.
3. Self-Employed Out-of-Hours or Relevant ICB Work
Forms A and B are not automatically the correct route for self-employed out-of-hours work or relevant ICB work.
Those arrangements can fall within the Solo pension process.
This distinction is important because a GP can perform several different NHS roles during the same year, each requiring a different pension treatment.
How Long Can a GP Locum Work at the Same Practice?
This is an important question that is often missed.
For NHS Pension Scheme purposes, freelance GP locum work is based on deputising or temporarily assisting a practice.
Current PCSE guidance explains that a period of six months or more at the same practice would not normally be regarded as deputising or temporarily assisting.
A GP working for one practice on a long-term self-employed basis may therefore need different pension treatment rather than continuing indefinitely with Forms A and B.
This means the words written on the invoice are not enough.
If a doctor has worked at the same surgery continuously for an extended period, the actual working arrangement should be reviewed.
GP Locum Pension Route: Quick Decision Table
| Working arrangement | Forms A & B? |
|---|---|
| Temporary freelance GP locum at a practice | Yes, potentially |
| Deputising for an absent GP | Yes |
| Qualifying freelance GP locum work | Yes |
| Locum invoicing through own limited company | No |
| GP provider locuming in own surgery | No |
| Self-employed OOH work falling within Solo rules | No — use relevant Solo process |
| Relevant self-employed ICB work | Usually separate Solo process |
| Ordinary salaried GP employment | No — employment pension process |
| Salaried GP + eligible freelance locum work | A/B for pensioned locum element plus Type 2 considerations |
Where the working pattern is complicated, the correct pension route should be established before months of incorrect submissions accumulate.
What Percentage of GP Locum Income Is Pensionable?
For qualifying freelance GP locum work under the Forms A and B process, the pensionable amount is:
90% of the basic locum fee
The employer contribution element is excluded when calculating the underlying fee.
You cannot simply choose to pension:
- 100%;
- 75%;
- 50%;
- or another convenient percentage.
For eligible work that you choose to pension through this process, the pensionable figure is 90% of the relevant basic fee.
Worked Example: £1,000 GP Locum Fee
Assume a freelance GP charges a basic fee of:
£1,000
Step 1 — Calculate Pensionable Pay
£1,000 × 90%
= £900 pensionable pay
Step 2 — Calculate Employer Contribution
For 2026/27, Form A uses an employer contribution and administration amount of:
14.38% of pensionable pay
£900 × 14.38%
= £129.42
Step 3 — Calculate Employee Contribution
Assume, for illustration only, that the GP’s correct employee contribution rate is:
12.5%
£900 × 12.5%
= £112.50
Summary
| Calculation | Amount |
|---|---|
| Basic locum fee | £1,000.00 |
| Pensionable pay — 90% | £900.00 |
| Employer contribution — 14.38% | £129.42 |
| Employee contribution — 12.5% example | £112.50 |
| Total employee + employer pension contribution | £241.92 |
The 12.5% figure is only an example.
The employee contribution rate in a real case depends on the GP’s correct 2026/27 contribution tier.
Who Pays the Employer NHS Pension Contribution?
For qualifying freelance GP locum work, the practice calculates the employer contribution on Form A.
For 2026/27, the amount shown through the locum process is 14.38% of the 90% pensionable pay.
That 14.38% includes the 0.08% administration levy.
The locum then pays the relevant employer and employee contributions through the applicable pension process.
This creates an important practical bookkeeping point:
The employer contribution is not simply additional locum profit to spend.
It is provided for the NHS pension contribution process.
Locums should therefore keep it identifiable in their bookkeeping and cash-flow records.
What Happens if You Decide Not to Pension the Locum Work?
A freelance GP can choose not to pension eligible locum work.
However, where the GP initially stated that the work would be pensioned and received the relevant employer pension contribution, that amount should not simply be retained as additional personal income if the work is ultimately not pensioned.
The practice should be informed and the employer contribution dealt with correctly.
This is another reason to decide how an engagement will be treated before the administration becomes complicated.
GP Locum NHS Pension Contribution Rates for 2026/27
The pensionable-earnings bands used to determine NHS pension contribution tiers were updated from 1 April 2026.
For freelance GP locums, the relevant rate ultimately depends on annualised GP pensionable income, not simply one month’s earnings.
| Annualised GP pensionable income | 2026/27 employee contribution rate |
|---|---|
| Up to £13,259 | 5.2% |
| £13,260–£28,854 | 6.5% |
| £28,855–£35,155 | 8.3% |
| £35,156–£52,778 | 9.8% |
| £52,779–£67,668 | 10.7% |
| £67,669 and above | 12.5% |
A GP should therefore not compare one month’s locum income with this table and assume that is automatically the correct rate.
Why Annualisation Matters for GP Locums
Annualisation is one of the most misunderstood parts of GP pension administration.
For relevant GP practitioner income, the contribution tier can be based on the income the GP would notionally have earned if their pensionable service had continued across a full year.
A simplified version of the calculation is:
Total relevant GP pensionable income ÷ pensionable days of service × 365 = annualised pensionable income
This can create a contribution rate that looks surprisingly high compared with the amount actually earned.
Why a GP Earning £30,000 Can Still Fall Into the 12.5% Tier
Consider a freelance GP locum with:
£30,000 pensionable GP income
earned over:
60 pensionable days
Annualising the income gives:
£30,000 ÷ 60 × 365
= £182,500 annualised pensionable income
That places the GP within the 12.5% contribution tier under the current 2026/27 bands.
The GP has not actually earned £182,500.
The figure is used to determine the appropriate contribution tier.
This is why short periods of high-intensity locum work can produce a higher contribution rate than a GP might expect simply from looking at the actual cash received.
Does Salaried GP Income Affect the Locum Contribution Tier?
It can.
Where a GP has other practitioner GP pensionable income, that income can need to be considered when determining the correct contribution rate.
For example, a doctor may have:
- salaried GP practitioner income;
- freelance GP locum income;
- relevant Solo income.
The correct tier cannot always be determined by looking at the locum earnings in isolation.
Does Hospital or NHS Officer Income Count Towards GP Locum Annualisation?
Not every NHS salary is treated in the same way.
An NHS post classified as an officer post, such as certain hospital employment, is pensioned through the employer’s payroll.
Current PCSE guidance states that officer income is not included as GP practitioner pensionable pay for the locum annualisation calculation.
This distinction matters for doctors with portfolio careers.
A GP might simultaneously have:
- hospital employment classified as officer service;
- salaried GP practitioner work;
- freelance GP locum work;
- private medical income.
Those income streams should not simply be added together without considering their pension classification.
What if You Use the Wrong Contribution Tier?
The contribution rate used during the year can be provisional.
As cumulative pensionable income changes, a GP may discover that the final contribution tier is different.
If the final rate should have been higher:
additional pension contributions may become payable.
If the GP has overpaid:
a refund may be due.
That makes accurate year-to-date pension records important.
Do not wait until the tax return is being prepared to ask what contribution rate was used throughout the year.
What Does Box J on Form B Do?
Form B includes cumulative freelance GP locum pensionable income.
For example:
June pensionable income:
£3,000
June cumulative figure:
£3,000
July pensionable income:
£4,000
July cumulative figure:
£7,000
The cumulative figure helps monitor pensionable income and the contribution tier during the year.
It is another reason why Form B should be treated as part of a monthly financial process rather than a once-a-year task.
GP Locum Pension Workflow in England
A practical workflow looks like this.
Step 1 — Confirm the Work Is Eligible
Before treating income as pensionable freelance GP locum income, confirm that the nature of the engagement falls within the locum rules.
Step 2 — Tell the Practice You Intend to Pension the Work
Make the pension treatment clear to the practice at the outset.
Step 3 — Complete the Locum Work
Maintain accurate records of:
- practice;
- dates;
- sessions;
- fee;
- invoice.
Step 4 — Raise the Invoice
Invoice the practice according to the agreed terms.
Step 5 — Submit Form A
Submit the relevant Form A information promptly.
In England, this can be done using PCSE Online.
Step 6 — Obtain Practice Approval
The practice reviews and approves the Form A information.
Do not assume this has happened merely because the invoice has been paid.
Step 7 — Complete Form B
Once the relevant Form A information has been approved, complete the monthly Form B process.
Step 8 — Pay Pension Contributions
PCSE Online can calculate the required contribution payment based on the information submitted.
Payments can be made through GOV.UK Pay.
Step 9 — Check the Employee Contribution Statement
Payment and submission should be reconciled to the locum’s pension records.
Step 10 — Retain Evidence
Keep copies of forms, payment confirmations and related financial records.
GP Locum Pension Monthly Checklist
| Timing | Action |
|---|---|
| Before/when accepting work | Confirm pension eligibility and intended treatment |
| Date work is performed | Record exact practice, dates and sessions |
| When invoicing | Record the correct basic fee |
| Promptly afterwards | Submit Form A |
| Following practice approval | Complete Form B |
| By relevant monthly deadline | Pay employee and employer contributions |
| Before work becomes 10 weeks old | Ensure the pension process remains compliant |
| Monthly | Reconcile forms and contribution payments |
| During the year | Review cumulative GP income and contribution tier |
| Year-end | Check final contribution rate and reconciliation |
A recurring monthly routine dramatically reduces the chance of a pensionable session being forgotten.
Do You Need One Form A for Every GP Locum Session?
Not necessarily.
Where several sessions or days:
- relate to the same practice;
- fall within the same relevant period; and
- are included on the same invoice,
they can potentially be included together, provided the actual work periods are properly recorded.
However, where separate invoices are raised for different periods of work, a separate Form A is required for the relevant invoice/occasion.
For example, if you invoice a practice weekly, the Form A process should follow the weekly invoicing pattern.
If you invoice monthly, several sessions during that month can potentially be included on the same Form A, provided all the relevant work dates are recorded correctly.
What if GP Locum Work Crosses Two Months?
Work spanning two calendar months should be separated appropriately.
For example:
29 June to 1 July
should be separated into:
29–30 June
and:
1 July
This supports the correct monthly pension administration and contribution records.
It is another reason accurate session diaries matter.
GP Locum Form A: Practice Responsibilities
GP practices also have an important role in the process.
The practice needs to check information including:
- dates worked;
- basic locum fee;
- 90% pensionable pay;
- employer pension contribution;
- the accuracy of the engagement details.
For practices using locums frequently, this should become part of the normal financial-control process.
| Practice task | Recommended action |
|---|---|
| Confirm work dates | Check against session records |
| Confirm basic fee | Exclude employer contribution |
| Calculate pensionable amount | Basic fee × 90% |
| Calculate employer contribution | Pensionable pay × 14.38% |
| Approve Form A | Do it promptly |
| Pay locum | Include correct pension element |
| Keep records | Retain supporting documentation |
| Avoid unnecessary delays | Help locum remain within the pension window |
GP practices that need help connecting pension administration, payroll, partnership accounts and locum costs can speak to our specialist GP practice accountants.
Why Practice Delays Can Cause GP Pension Problems
A GP can submit their part of the process promptly and still encounter problems where practice approval is delayed.
Imagine Form A sits awaiting approval for several weeks.
The underlying work continues to age while the administration remains incomplete.
That can move the engagement dangerously close to the 10-week deadline.
Practices should therefore treat locum pension approvals as time-sensitive financial administration rather than something to review at year-end.
Does a Locum-Only GP Need a Type 2 Self Assessment?
Normally, no.
A GP who only undertakes freelance locum work does not generally need to complete a Type 2 pension self-assessment simply because they are a locum.
Eligible pensioned freelance work is administered using the locum process.
However, the position changes when the GP has other practitioner roles.
What if You Are Both a Salaried GP and a Locum?
Where a doctor has a salaried GP role and also performs freelance locum work, the two elements interact.
The GP can choose whether eligible freelance locum work is pensioned.
Where they choose to pension the locum work:
- Forms A and B are used for the eligible locum element; and
- relevant locum contributions must also be dealt with correctly within the Type 2 reconciliation.
This is one of the most common situations in which locum pension administration becomes more complex.
GP Pension Forms by Working Pattern
| GP income pattern | Locum A/B | Year-end pension position |
|---|---|---|
| Freelance locum only | Yes, for eligible pensioned work | No Type 2 solely because of locum work |
| Salaried GP only | No locum forms | Type 2 |
| Salaried GP + pensioned freelance locum | Yes for locum element | Type 2 |
| Salaried GP + non-pensioned locum | No A/B for non-pensioned work | Type 2 still applies to salaried GP role |
| Officer post + freelance locum | A/B for eligible locum work | Officer income handled through payroll; locum-only position does not itself create Type 2 |
| Solo/OOH + locum where practitioner rules apply | Different processes may apply to each role | Type 2 can be required depending on underlying practitioner roles |
| GP partner + external eligible locum work | A/B may apply to eligible external locum work | Type 1 practitioner reconciliation remains relevant |
Do not assume one pension form covers every GP income source.
Can a Salaried GP Choose Whether to Pension Additional Locum Work?
Yes.
A salaried GP can choose whether eligible additional freelance locum work is pensioned.
If it is pensioned, the locum administration must still be completed within the required timetable.
The pensioned locum contributions then need to be reflected appropriately in the doctor’s wider practitioner pension reconciliation.
Does GP Locum Pension Income Affect the NHS Annual Allowance?
Potentially.
Pensioning additional GP income can increase NHS pension benefits and therefore affect pension growth.
However, there is an important distinction:
the amount of employee contributions paid is not the same as the Annual Allowance calculation.
The NHS Pension Scheme is primarily a defined-benefit arrangement.
For Annual Allowance purposes, the relevant calculation is based on the increase in the value of pension benefits known as the Pension Input Amount rather than merely adding together the cash contributions paid during the year.
Higher-earning locum GPs may therefore need to consider:
- NHS pension growth;
- salaried GP or partnership income;
- private pension contributions;
- threshold income;
- adjusted income;
- tapered Annual Allowance;
- available carry forward;
- Scheme Pays.
Our detailed NHS Pension Annual Allowance 2026/27 guide explains this calculation separately.
Locum Contributions Are Not the Annual Allowance Figure
Suppose a GP personally pays:
£10,000 of NHS pension contributions
That does not automatically mean £10,000 has been used against the Annual Allowance.
The Annual Allowance measures pension growth under specific tax rules.
A doctor can therefore have:
- relatively modest cash contributions but significant pension growth; or
- substantial contributions without an equivalent Annual Allowance figure.
Locum GPs with high income or several pensionable roles may consequently need both a contribution reconciliation and a separate Annual Allowance review.
How GP Locum Pension Records Connect With Self Assessment
A genuinely self-employed GP locum may also have several tax-reporting obligations.
Income could include:
- freelance locum fees;
- salaried PAYE income;
- private clinical work;
- medico-legal income;
- teaching income;
- rental income;
- investment income;
- limited-company income from separate activities.
The tax return and pension records should therefore be reconciled against the same underlying financial information.
A discrepancy does not always mean an error, but the accountant should understand why the numbers differ.
Our personal tax services for healthcare professionals include support for doctors with mixed PAYE, self-employed and professional income.
Why Bookkeeping Matters for Locum GPs
Good locum pension administration depends on good underlying records.
A GP should ideally be able to reconcile the following:
| Record | What it confirms |
|---|---|
| Session diary | When work was actually performed |
| Invoice | Fee charged |
| Bank receipt | Payment received |
| Form A | Pensionable engagement |
| Form B | Monthly pension contribution summary |
| PCSE/GOV.UK Pay record | Contributions paid |
| Employee Contribution Statement | Pension contribution record |
| Accounts | Professional income |
| Self Assessment | Final tax reporting |
You may therefore see three different numbers associated with the same engagement.
For example:
£1,000 — basic fee
£900 — 90% pensionable pay
£1,129.42 — basic fee plus the 14.38% employer contribution calculated on pensionable pay
Those figures can all be correct.
They simply represent different parts of the transaction.
Worked Case Study: Freelance GP Locum
Dr Patel performs four eligible temporary sessions at one GP practice during September 2026.
The basic locum fee is:
£3,200
Pensionable Pay
£3,200 × 90%
= £2,880
Employer Contribution
£2,880 × 14.38%
= approximately £414.14
Employee Contribution
Assume Dr Patel’s correct annualised pensionable income puts them in the 12.5% tier.
£2,880 × 12.5%
= £360
Contribution Summary
| Element | Amount |
|---|---|
| Basic fee | £3,200.00 |
| Pensionable pay | £2,880.00 |
| Employee contribution | £360.00 |
| Employer contribution | £414.14 |
| Total employee + employer contributions | £774.14 |
Dr Patel should not wait until March 2027 to organise the September 2026 pension paperwork.
The monthly administration should be completed while the work is current and comfortably within the applicable deadline.
Common GP Locum Pension Mistakes
| Error | Potential consequence |
|---|---|
| Waiting until tax year-end to submit forms | Work can fall outside the 10-week window |
| Treating 100% of the basic fee as pensionable | Incorrect pension calculation |
| Selecting the wrong employee contribution tier | Arrears or refund later |
| Ignoring annualisation | Wrong contribution rate |
| Forgetting other relevant practitioner GP income | Incorrect tier |
| Using A/B forms for limited-company invoices | Work is not eligible through this route |
| Using standard A/B forms for work that belongs under Solo | Wrong pension process |
| GP partner treating own-practice work as freelance locum income | Incorrect pension treatment |
| Practice delaying Form A approval | Increases deadline risk |
| Recording incorrect work dates | Pension service may be wrong |
| Keeping no copies | Difficult year-end reconciliation |
| Salaried GP omitting pensioned locum contributions from Type 2 | Pension mismatch |
| Treating employer contribution as extra disposable income | Contribution shortfall |
| Assuming late payment restarts the 10-week period | Work may become non-pensionable |
| Continuing A/B treatment indefinitely at one practice | Engagement may no longer qualify as temporary locum work |
GP Locum Pension Red-Flag Checklist
A specialist review may be worthwhile where:
- Forms A or B appear to be missing;
- several months of locum work were never pensioned;
- the correct employee contribution tier is unclear;
- you combine salaried and freelance GP work;
- you combine officer and practitioner roles;
- Type 2 figures do not agree with the locum records;
- you have invoiced through both personal and limited-company arrangements;
- your NHS pension record contains unexplained gaps;
- annualisation has never been reviewed;
- you have received unexpected pension arrears;
- there is a possible NHS Annual Allowance issue;
- your accountant has never requested your GP pension records.
These are not automatically evidence that something is wrong.
They are signs that the records deserve a closer look.
Can Old GP Locum Work Be Pensioned Retrospectively?
Normally not through the standard freelance GP locum process once the work is outside the applicable 10-week window.
This is why Forms A and B should not be stored in a folder marked:
“Deal with at tax year-end.”
They are monthly pension-administration documents.
The tax return can be prepared later.
The pension deadline cannot simply be recreated later because the bookkeeping was delayed.
Can You Pension Only Part of the 90%?
No.
Where qualifying freelance locum work is pensioned through this process, pensionable pay is 90% of the relevant basic fee.
The GP cannot decide to pension:
- 30%;
- 50%;
- 70%;
- or another chosen percentage.
The decision is broadly whether qualifying work will be pensioned through the applicable process, not what percentage of the prescribed pensionable amount the doctor would prefer to use.
Can a GP Locum Work for Several Practices?
Yes.
Working for several practices does not itself prevent a GP from pensioning qualifying freelance locum work.
The challenge is administration.
The locum needs accurate records for each engagement, including:
- practice;
- dates;
- sessions;
- invoices;
- Forms A;
- Form B totals;
- contribution payments.
The more practices a GP works for, the more important monthly reconciliation becomes.
GP Locum Pension Rules and Employment Status Are Not the Same Thing
NHS pension classification and tax employment status should not automatically be treated as identical.
An engagement may need consideration under:
- NHS Pension Scheme rules;
- employment-status rules;
- IR35/off-payroll rules;
- Self Assessment rules;
- PAYE rules.
The fact that a doctor is called a “locum” does not settle all of those issues.
Similarly, the fact that an engagement qualifies for one particular pension treatment does not by itself determine the tax treatment of the arrangement.
Doctors working through intermediaries, agencies or personal service companies should therefore consider the employment-status position separately.
What Records Should a GP Locum Keep?
At a minimum, keep:
| Document | Why it matters |
|---|---|
| Engagement terms | Shows nature of arrangement |
| Session diary | Confirms actual dates worked |
| Invoices | Supports basic fee |
| Approved Forms A | Evidence of pensionable engagements |
| Forms B | Monthly pension records |
| Contribution receipts | Evidence of payments |
| PCSE records | Confirms submissions |
| Employee Contribution Statements | Supports pension reconciliation |
| P60s | Relevant for salaried/other employment |
| Type 2 forms | Where applicable |
| Tax returns | Wider income reconciliation |
| Pension Savings Statements | Annual Allowance reviews |
| Limited-company records | Important where different structures were used |
Good records are particularly important when a GP has changed working patterns during the year.
What Should a Specialist NHS Pension Accountant Check?
A useful pension review should go beyond checking the arithmetic on Form B.
It should ask:
Work
What sessions were actually performed?
Income
What was invoiced, and what was eventually paid?
Pension Eligibility
Which engagements genuinely qualified for the freelance locum process?
Forms
Were Forms A and B completed consistently with the underlying work?
Contributions
Were the employee and employer amounts calculated correctly?
Contribution Tier
Was annualisation considered properly?
Other GP Income
Was other relevant practitioner pensionable income included where necessary?
Officer Income
Was separate officer employment correctly distinguished from practitioner income?
Type 1 or Type 2
Were the correct year-end practitioner forms used?
Annual Allowance
Does the resulting NHS pension growth need a separate pension-tax review?
This is why NHS pension work can become considerably more complex than ordinary bookkeeping.
How Kudos Accounting Supports Locum GPs
Locum GP finances can involve several systems simultaneously:
- NHS Pension Scheme;
- PCSE;
- Self Assessment;
- PAYE;
- Making Tax Digital;
- limited-company accounts;
- employment-status questions;
- Type 2 pension reconciliation;
- Annual Allowance calculations.
A general tax-return review may therefore not identify every pension issue.
Our locum doctor accountants help doctors reconcile PAYE, self-employed, private and company income, while our NHS Pension Accountants can support pensionable-earnings reconciliation, relevant Type 1 and Type 2 records, pension discrepancies and Annual Allowance calculations.
The objective is not simply to complete another form.
It is to make sure that the GP’s work records, accounting records, pension records and tax reporting tell the same financial story.
Final Takeaway
The biggest risk with GP Locum Forms A and B is often not difficult arithmetic.
It is allowing the administration to fall behind.
For qualifying freelance GP locum work in 2026/27, a sensible process is:
confirm eligibility → record exact work dates → invoice correctly → submit Form A → obtain practice approval → complete Form B → pay the required contributions → reconcile the pension record
The key numbers are relatively straightforward:
- 90% of the qualifying basic locum fee is pensionable;
- the 2026/27 employer contribution and administration amount used on Form A is 14.38% of pensionable pay;
- employee contribution rates currently range from 5.2% to 12.5%;
- the final employee rate can depend on annualised GP pensionable income.
The more difficult issues arise when the GP:
- works through a limited company;
- has several practitioner roles;
- combines salaried and locum work;
- has separate officer employment;
- performs OOH or Solo work;
- works long-term at one practice;
- has missing pension records;
- or faces an Annual Allowance question.
These are exactly the circumstances where pension administration should be reviewed alongside the doctor’s wider accounting and tax position.
If your Forms A and B, contribution history or NHS pension record do not agree, contact Kudos Accounting for a specialist review.
Frequently Asked Questions About GP Locum Forms A and B
Clear answers to common questions about GP Locum Forms A and B, PCSE, pension contributions, the 10-week rule, contribution tiers and mixed GP working arrangements.
FORM A What is GP Locum Form A?
GP Locum Form A records a qualifying individual freelance GP locum engagement, including the actual dates worked, the basic fee, the 90% pensionable pay and the employer NHS pension contribution. In England, the information can be submitted through PCSE Online for approval by the relevant practice.
FORM B What is GP Locum Form B?
GP Locum Form B is the monthly summary of pensionable freelance locum income and associated employee and employer pension contributions. It also records information used to monitor the GP’s contribution tier and cumulative pensionable locum income.
10-WEEK RULE What is the GP locum NHS pension 10-week rule?
Qualifying freelance GP locum work cannot normally be pensioned through the standard Forms A and B process once it falls outside the 10-week pensioning window. A practice paying the invoice late does not simply restart that deadline, so locum pension administration should be completed promptly.
90% RULE How much of a freelance GP locum fee is pensionable?
For qualifying work pensioned through the freelance GP locum process, pensionable pay is 90% of the basic fee, excluding the employer contribution element. The GP cannot choose a different percentage for work they decide to pension through this process.
EMPLOYER CONTRIBUTION What is the employer NHS pension contribution for a GP locum in 2026/27?
For 2026/27, GP Locum Form A uses an employer contribution and administration amount of 14.38% of the 90% pensionable pay. The amount includes the administration levy and forms part of the pension contribution process rather than ordinary additional locum profit.
LIMITED COMPANY Can I pension GP locum income received through my limited company?
Not through GP Locum Forms A and B. Where the invoice is issued by the doctor’s limited company, the income is not eligible to be declared through the standard freelance GP Locum Form A process.
TYPE 2 Does a GP who only performs freelance locum work need Type 2?
Normally no. PCSE states that a GP who only performs freelance locum work does not need to complete Type 2 solely because of that locum work. Eligible pensioned freelance locum income is administered through Forms A and B.
SALARIED + LOCUM What if I am both a salaried GP and a freelance locum?
A salaried GP can choose whether eligible additional freelance locum work is pensioned. Where it is pensioned, Forms A and B are used for the eligible locum element and the relevant pensioned locum contributions also need to be dealt with appropriately within the Type 2 reconciliation.
SAME PRACTICE How long can a GP locum work at the same practice?
For NHS pension purposes, freelance GP locum work involves deputising or temporarily assisting a practice. Current PCSE guidance states that a period of six months or more at the same practice would not normally be considered temporary locum work, so a longer-term engagement should be reviewed for the correct practitioner pension treatment.
ANNUALISATION Why can my NHS pension contribution rate be higher than expected?
GP practitioner pensionable income can need to be annualised when establishing the correct contribution tier. As a result, a GP who earns a relatively modest amount over a short period can fall into a higher tier once that income is annualised over the relevant period of pensionable service.
OFFICER INCOME Does hospital NHS salary count towards GP locum annualisation?
Not where the hospital employment is classified as an NHS Pension Scheme officer post. Officer income is pensioned through the employer’s payroll and is treated separately from GP practitioner income for the locum annualisation calculation.
OUT-OF-HOURS Can GP out-of-hours income be pensioned using Form A?
Not automatically. Self-employed out-of-hours and relevant ICB work can fall within the separate Solo pension process rather than the standard GP Locum Forms A and B route. The exact treatment depends on the underlying working arrangement.
LATE FORMS Can I pension GP locum work retrospectively after the 10-week deadline?
Normally not through the standard freelance locum process once the work is outside the applicable 10-week window. This is why Forms A and B should be treated as monthly pension administration rather than documents to organise at tax year-end.
SPECIALIST REVIEW When should a locum GP get specialist pension help?
A review can be particularly useful where Forms A or B are missing, the correct contribution tier is unclear, you combine salaried and locum roles, Type 2 figures do not reconcile, you have worked through different business structures, your pension record contains unexplained gaps or there is an NHS Annual Allowance concern.
Do Your Locum Forms, Contributions and NHS Pension Records All Match?
A missing Form A, incorrect contribution tier or unresolved pension-record gap can become considerably harder to correct later. A structured monthly process helps keep your locum work, pension contributions, accounting records and year-end reporting aligned.
Get your GP locum pension records reviewed before unresolved gaps become harder to correct
Kudos Accounting supports locum GPs with pensionable-income reconciliation, contribution records, Locum Forms A and B information, Type 2 records, NHS Annual Allowance calculations and related tax reporting. Learn more about our specialist NHS Pension Accountant service.