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HMRC guidance and remuneration of coastguard volunteers

On Wednesday 1 July 2026 there will be a Westminster Hall debate on the remuneration of Coastguard volunteers. The debate will take place between 2.30pm and 4pm, and will be opened by Alistair Carmichael MP.

The Coastguard Rescue Service

The Coastguard Rescue Service is largely delivered by coastguard rescue officers. They respond to emergency situations on the coastline, such as helping people trapped on cliffs, stuck in mud or struggling in water. In 2024/25, the Coastguard Rescue Service had “over 3,500 Volunteers in 287 teams in local communities throughout the UK”, led by “over 100 employed operational staff” (PDF).

The Coastguard Rescue Service is part of HM Coastguard, which is responsible for coordinating search and rescue operations at sea and on the coastline. HM Coastguard works with other emergency services as part of search and rescue operations. It can also call on other voluntary organisations to support operations, such as the Royal National Lifeboat Institution and other independent lifeboat organisations. It has a fleet of helicopters and planes, which are contracted out to Bristow Helicopters.

HM Coastguard is part of the Maritime and Coastguard Agency (MCA), itself an executive agency of the Department for Transport. The MCA states that HM Coastguard responded to 39,147 incidents (PDF) in 2024/25.

The MCA has wider responsibilities, including promoting and administering the UK Ship Register, responding to pollution events at sea, enforcing compliance with maritime rules, inspecting ships, and managing shipwrecks.

What’s the issue?

Currently CROs receive hourly remuneration for many of their activities while they are on duty (for example, responding to call-outs).

However, from September 2026 they will only be eligible to claim back expenses, and hourly remuneration will no longer be available.

This is due to a Court of Appeal judgment in Maritime and Coastguard Agency v Martin Groom [2026] EWCA Civ 6. While the MCA engaged CROs as volunteers and therefore not party to any worker/employer contract, the Court of Appeal (upholding a judgment by the Employment Appeal Tribunal) determined that they held the employment status of workers. This entitles them to some employment rights, such as paid holiday and the right to be paid the National Minimum Wage (NMW).

As a result of the judgment the MCA has proposed a new model for volunteer CROs. The MCA made a recommendation to the government that the new model would not include hourly remuneration. The minister, Parliamentary Under-Secretary at the Department for Transport Keir Mather accepted the recommendation. The new volunteer model is due to come into force in September 2026.

Employment status and the definition of worker

There are three different types of employment status recognised in employment law, applicable to those providing services on the job market:

• Employed
• Worker
• Self-employed

Lady Hale in Bates van Winkelhof v Clyde & Co LLP [2014] UKSC 32 described ‘workers’ as “[…] provid[ing] their services as part of a profession or business undertaking carried on by someone else”, as opposed to a self-employed person who carries on such undertaking “on their own account and enter into contracts with clients or customers to provide work or services for them.”

The difference between these types of employment is not always clear-cut, which has given rise to several legal cases. There is a growing body of case law relating to establishing specific people’s employment status.

Establishing the correct employment status is significant because different statues make someone eligible for different employment rights. In general employees have the ‘full set’ of employment rights, whereas workers are only eligible for some (such as entitlement to the NMW and whistleblowing protection). The Library briefing Employment status has more detail on this.

How is a ‘volunteer’ defined?

There is no single definition of ‘volunteer’ in law. The Department for Business and Trade gives a general definition of who counts as a volunteer. It includes people whose arrangement with an organisation does not entitle them to any financial reward or comparable benefit; who do not have to turn up to carry out their tasks if they don’t want to; and cannot be dismissed, sued, or have any payments withheld if they fail to perform the services provided. Generally volunteers are entitled to claim reasonable expenses, such as food or travel.

A volunteer in the traditional sense would not be classed as an employee or a worker. However there have been instances where the courts have found that some people who were classed as ‘volunteers’ by their organisations were, in legal terms, employees or workers (for example, Migrant Advisory Service v Chaudri [1998] UKEAT/1096/99).

What is the current model for volunteer coastguards?

While the documents setting out the relationship between the MCA and volunteer CROs are not available publicly, several elements were quoted in the Court of Appeal judgment in MCA v Groom [2026].

What do CROs do?

CROs are part of HM Coastguard, and may have to undertake activities such as rescuing people on cliffs, stuck in mud or in the water, search for missing people, or support emergency services during emergencies (such as during a flood).

In the MCA’s Volunteer Handbook, quoted by the Court of Appeal, the MCA outlines the relationship between CROs and the MCA:

The relationship between the Maritime and Coastguard Agency and its Coastguard Rescue Service volunteers is a voluntary two-way commitment where no contract of employment exists.

The Handbook also includes commitments that CROs have to abide by, such as:

• Abiding by the Code of Conduct
• Attending training and emergency response call-outs
• Comply with instructions applicable to activities of the Coastguard Rescue Service

Remuneration of CROs

According to the MCA’s Remuneration Document, CROs “may wish to claim remuneration for time, travel and expenses associated with specific activities undertaken […]”

Remuneration included both claims for expenses, and hourly remuneration. The Court found that CROs received payslips separating hourly remuneration and expenses: a P60 was issued at the end of the year, and a P45 upon termination. At the time of the Court of Appeal judgment the hourly rate of remuneration was not lower than the National Minimum Wage (NMW), although recent media reports suggest that the current hourly rate is now lower than the NMW rate.

Case summary

Martin Groom was a volunteer Coastguard Rescue Officer (CRO) for the Maritime and Coastguard Agency (MCA) from 1985 until his dismissal in 2020. CROs are entitled to receive remuneration for the activities they undertake. This is divided between hourly remuneration and separate ways to claim money back for travel and other expenses. Following a disciplinary matter, Mr Groom asked to be accompanied to a hearing by a trade union official, however the MCA denied this request. Workers and employees have a statutory right to be accompanied to disciplinaries under section 10 of the Employment Relations Act 1999; however volunteers in the traditional sense do not. Mr Groom brought a case to the Employment Tribunal to establish whether him (and by extension other CROs) should be considered workers rather than volunteers.

The Employment Tribunal rejected Mr Groom's case and held that CROs were volunteers. However, the Employment Appeal Tribunal overturned this decision, and the Court of Appeal upheld the Appeal Tribunal's findings, determining that CROs are workers and not volunteers.

Why has it been established that CROs are workers?

The Employment Appeal Tribunal, the decision of which was upheld by the Court of Appeal, chiefly focused on the elements of remuneration and mutuality of obligation in establishing that CROs were workers, and not volunteers.

CROs are asked to comply with the contents of a Code of Conduct document, which among other things set out a minimum attendance requirement. In addition, the remuneration document outlined the terms of payment: hourly pay was provided for many activities, payslips were issued and CROs were also entitled to claim back expenses. The Court of Appeal said that the contents of these documents created a "wage/work bargain".

Additionally, the Court, upholding the Appeal Tribunal’s judgment, said that a relationship between a worker and its employer is different than that of a volunteer and the organisation it volunteers for, because there is a "mutuality of obligations". The Court said that the concept of "mutuality of obligation" was closely aligned to whether a worker contract existed. The Court held that such mutuality of obligation existed while CROs were carrying out their duties, because:

• The CRO had an obligation to comply with reasonable instructions while on duty
• The MCA had an obligation to "make payment on receipt of a claim for attendance for relevant activities

As a result, the Court held that it was clear that legal relations existed while a CRO was carrying out a duty:

In those circumstances it seems to be quite unreal to say that there was no intention to create legal relations between the parties. As the [Employment Appeal Tribunal] found, a contract comes into existence when a CRO attends for an activity in respect of which there is a right to claim remuneration.

Consequences of the judgment

The main public statements made by the government resulting from the judgment have been made through answers to parliamentary questions (PQs).

Maritime Minister Keir Mather said that the Court of Appeal’s judgment meant that “the current [volunteer] model could not legally continue”, although it was not a change the government had sought. The minister provided further information about the process the MCA undertook to agree the new volunteer model:

Careful consideration was given to the options for a revised operating model. The legal position, the operational implications, the wider organisational impact and the effect on individuals have all been considered, as well as the feedback Coastguard Rescue Officers (CRO) have given us through recent surveys and engagement.

Moving to a model of volunteers with expenses but with no hourly remuneration was the best option to protect people’s choice to continue to serve their communities. Feedback from members of the Coastguard Rescue Service overwhelmingly indicated that the primary motivation for volunteering is to serve local communities and save lives. The volunteer model enables flexibility and the ability for people to volunteer alongside their primary employment.

Several expert commentators have said that the Court of Appeal judgment could have wider repercussions on organisations that rely on volunteers, and especially if the volunteers are entitled to any form of compensation. Law firm Birketts has said it would be “sensible for organisations to review the use of volunteers and consider the practical implications that this judgment may have.”

What are existing CROs entitled to as a result?

Maritime Minister Keir Mather said that serving CROs can receive compensation for up to the previous six years of service. He added that “the MCA will calculate each person’s entitlement and contact individuals.”

No cumulative assessment of how much this is expected to cost the government has been published to date.

What will CROs be entitled to receive from September 2026?

Minister Keir Mather said in answer to a PQ that under a new Expenses Policy, volunteers will be able to “claim non-taxable reimbursements for reasonable costs including travel, meals, equipment, accommodation, and other authorised expenses incurred in connection with their duties.”

Are other elements of the volunteer model changing?

Neither the government nor the MCA have published new documentation that is due to apply to CROs from September 2026. There is no information in the public domain as to whether other elements of the volunteer arrangement between CROs and the MCA are due to change.

Parliamentary and wider debate

House of Commons

There has been significant interest in this topic from MPs. This has particularly taken the form of written parliamentary questions, and several Members have also brought the subject up during Oral Questions to the Department for Transport. Primarily MPs have expressed concern at the changes and have asked the government to ensure this would not have detrimental effects on the resilience of coastguard rescue operations.

Alistair Carmichael (Liberal Democrat), the MP who will open the debate this briefing refers to, brought up this topic during Business Questions on 18 June 2026. Mr Carmichael asked for a debate in government time on the MCA’s proposed changes to the compensation of CROs, citing the “massive concern” the MCA’s proposals were causing CROs in his constituency. Answering, Leader of the House Sir Alan Campbell suggested he could help the Member arranging a meeting with the Transport Minister (Mr Mather).

This is the first parliamentary debate on the matter since the government confirmed hourly remuneration for CROs would be stopped.

Petitions

In April 2026 a petition was published calling on the government to introduce legislation “to make it possible to remunerate emergency volunteers”, specifically highlighting the legal case involving Martin Groom and the MCA.

As the petition has surpassed 10,000 signatures, the government will respond to it.

Early Day Motion

On 10 June 2026 an Early Day Motion (EDM) on Coastguard remuneration was published. Ben Maguire (Liberal Democrat) was the first signatory. The text of the EDM expresses concern about the changes in the volunteer model, particularly in coastal tourist spots where visitors are unfamiliar with local conditions. The motion “warns that [the removal of payment] creat[es] substantial and potentially irreversible gaps in service provision.”

The EDM has been signed by 35 MPs so far.

Other organisations

The GMB Union, who had brought the case with Martin Groom, said that the decision by the MCA to withdraw hourly remuneration for emergency call-outs was a “reprehensible move.” The GMB said it would support CROs following the MCA’s decision.

On 24 June The Guardian reported that CROs and the GMB Union are due to meet with MPs on 1 July.