If you’re a recruitment agency working with UK umbrella companies, you may want to listen up! There is a countdown to a seismic shift in your legal and financial liability!

In April 2026, new HMRC legislation, Chapter 11 of ITEPA 2003, will come into effect. It’s designed to crack down on tax fraud in the umbrella sector. And here’s why it affects you.

This law introduces a term you need to fear: Joint and Several Liability (JSL) for unpaid PAYE and National Insurance. Simply put: if an umbrella company fails to pay the correct tax on a worker you supplied, HMRC will come directly to your agency for the entire bill.

And I need to be clear: There is no defence. You can’t plead ignorance. You can’t say, “We did reasonable care checks.” Your liability is absolute. This risk sits squarely on the top agency—the one contracting with the end client.

This is separate from, but interacts with, your existing obligations under Chapter 7—the Supervision, Direction, and Control (SDC) test. If SDC applies, the worker is an employee. You need robust evidence to prove they’re self-employed. And fraudulent documents from an umbrella company? No longer a defence.

The message is simple: Due diligence must be water-tight. You must continuously vet your umbrellas. Check their financial health and compliance processes, and verify their payslips. This is about saving your business from unexpected, catastrophic tax debt.

So, how do you manage this existential risk? You need specialist support. That is why many agencies are turning to us at Access Financial. We can provide the expertise to manage this new regulatory battlefield.

We don’t just process payments; we provide a shield against the new JSL rules. By outsourcing your payroll to Access Financial, you can eliminate liability and gain peace of mind. We handle all employment agreements, payroll, and administration, effectively removing the JSL bullseye from your back.

April 2026 is approaching fast. Your current model of operation may carry an unacceptable level of risk. Don’t wait for HMRC to send you the bill for someone else’s mistake.

Click the link below to contact Access Financial and secure your agency’s future today!

https://accessfinancial.com/get-started/a-recruitment-agency/