You may have just got your organisation IR35 compliant. But with IR36 looming, have you updated your processes, or are you risking a rather unexpected sanction?
In the latest evolution of off-payroll working rules, driven by the rapid rise of AI over the past 12 months (and the not-so-small matter of declining tax revenues), a third worker classification is now being proposed.
Not just employed or non-employed but now “Avatar”.
This new category is designed to capture the growing use of semi-autonomous, AI-powered delivery, as consultants increasingly deploy digital resource alongside (or instead of) humans.
As tax expert H. Cokey explains:
“It’s no longer about whether you are in, or out, everything is being all shaken-about.”
So… are your processes ready?
Or are you still operating as a human-only buyer in an AI-enabled world?
If you want to know what’s actually going on in consultancy procurement (IR36 or otherwise), join us at the CPC Annual Summit.
Join the conversation?
Thursday 16 April 2026 | Fenchurch Place, London
The CPC Annual Summit brings together 150+ senior procurement and commercial leaders responsible for consultancy spend to share insight, challenge thinking and explore the future of the category.
FREE for professionals responsible for consultancy spend, including Heads of Professional Services and Consultancy Category Managers.
To register or find out more, please contact: jodie.heath@thecpcouncil.com or register using this link.


