April 2026

What are the anticipated changes in April 2026, and how can we prepare?

Published in July 2025 under the policy paper 'Umbrella companies — tackling non-compliance in the umbrella company market', legislation will be introduced in Finance Bill 2025-26 to amend part 2 of ITEPA 2003. The legislation will introduce a new chapter 11 into part 2 to make employment agencies or end clients joint and severally liable for any amount required to be accounted for under the PAYE provisions where an umbrella company forms part of a labour supply chain.

Further legislation will be introduced to amend section 4A of Social Security Contributions and Benefits Act1992 to provide HM Treasury with the power to make regulations imposing an equivalent joint and several liability for NIC purposes.

In short, Joint and Several Liability will allow HMRC to pursue an agency in the first instance for any payroll taxes that a non-compliant umbrella company fails to remit to HMRC on their behalf. The end client will be liable if contracting directly with an umbrella company.

Understanding Joint & Several Liability

Industry experts John Chaplin (Tax Partner, BDO) and Shaun Critchley (Chairman, ADVANCE) discuss what Joint & Several Liability is, how it may affect stakeholders within the contracting supply chain, and what you can be doing to manage risk.

 

View the trailer here

John Chaplin, Tax Partner at BDO, and Shaun Critchley, Chairman of Advance explain the fundamentals of Joint and Several Liability, why it is being introduced, and what it means for agencies and umbrellas across the contracting supply chain. This opening chapter sets the scene for April 2026 and outlines why every organisation needs to understand where accountability will now sit.

Joint & Several Liability : What is it?

HMRC’s powers under the new legislation are broader than many expect. This chapter explores how enforcement works in practice, including HMRC’s right to pursue the party most able to pay, what triggers investigations, and how compliance interventions will be carried out.

Joint & Several Liability : What can HMRC do

Understanding where liability attaches is essential for agencies, umbrellas, and end clients alike. John and Shaun break down how PAYE, NIC, and apprenticeship levy responsibilities flow through the supply chain, and where agencies may find themselves unexpectedly exposed.

Joint & Several Liability : Where does liability attach itself to?

Even the best-run umbrella can face commercial or operational failure. This discussion covers what happens if an umbrella collapses mid-contract, who picks up the liability, and what practical steps agencies can take to protect themselves before that happens.

Joint & Several Liability : What happens when the unexpected happens?

Past behaviour still matters. In this section, the focus turns to umbrellas with historic tax or compliance issues and how that history could impact agencies once the new regime begins. The discussion clarifies how to identify risk early and what due diligence should be performed.

Joint & Several Liability : What about retrospective problem umbrella providers?

The new framework affects everyone, not just large recruitment firms. This chapter outlines what smaller agencies can do to manage exposure effectively, how to prioritise suppliers, and why a clear internal compliance process will be more important than ever.

Joint & Several Liability : What about small to medium agencies managing their risk?

Here, both experts walk through practical measures agencies should adopt, from verifying PAYE payments in real time to maintaining tighter PSLs and monitoring umbrella partners continuously. It is a clear checklist for proactive risk management in a higher-stakes environment.

Joint & Several Liability : How does an agency manage risk?

This chapter examines how the promotion of tax avoidance schemes fits within the wider Joint and Several Liability framework. John explains how existing rules are being tightened and what agencies need to watch for when reviewing supplier models or marketing claims.

Joint & Several Liability : Legislation about promotion of tax avoidance schemes.

The session closes by exploring the overlap between Joint and Several Liability and the Corporate Criminal Offences regime. The discussion highlights how ignorance will no longer be a defence and why governance, oversight, and documented compliance now carry real weight.

Joint & Several Liability : How strict is the legislation on corporate criminal offences?

How ADVANCE can help agencies and their clients

We are offering technical and tailored advice, workshops, client visits & support to ensure you and your clients understand the impact of the legislation changes expected over the coming months. Working with ADVANCE puts you in safe hands with our range of services and market leading solutions.

 

Call today on 01244 564 564