IN FORCE: 6 April 2026
New umbrella company tax legislation introducing joint and several tax liability between the umbrella company and the agency (or in some cases the end hirer) for any failure by the umbrella company to pay full PAYE and NICs to HMRC came into effect from April 2026.
Ongoing
• A consultation on bringing umbrella companies within the regulatory framework for the temporary labour market closes 1 May 2026.
• The main regulatory framework is expected to be in force 2027.
- Action
- The joint and several tax liability provisions are now in force. Employers (agencies and hirers) engaging umbrella company workers should urgently review their arrangements to understand their potential exposure and ensure that appropriate contractual protections and due diligence processes are in place.
- Monitor the outcome of the consultation on bringing umbrella companies within the regulatory framework for the temporary labour market.
- In detail
Please read our latest updates or speak to your usual Osborne Clarke contact to understand the impact for your working model:
