Are we under CIS?

We manage grant funding for retrofit home improvements. This involves us in 3 main areas. Firstly we assess the options for householders to improve the energy efficiency of their homes and agree which ones they are going to do. Secondly we link up a member installer (we are a cooperative with our members being installers etc). Members are charged an introduction fee for the lead. Thirdly, once the work in complete we claim the funds from the Grant provider (usually a local authority) and we pass them on to the installer on behalf of the householder. For managing this process we charge a management fee to the Grant provider. we have been asked to operate under CIS however we are not directly in construction, we provide a service to manage grant funds and to introduce suppliers to business opportunities. We don't provide any materials or labour. My sense is that we don't fall under CIS, but would appreciate any other views please.

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