From 6 April 2026, agencies and end clients using umbrella companies, payroll intermediaries or third-party labour suppliers face a sharper compliance question:
Can you prove who is responsible for PAYE in your labour supply chain?
If your business uses agency workers, umbrella companies, subcontracted labour or outsourced payroll arrangements, now is the time to review the paperwork.
HMRC's new PAYE rules for labour supply chains involving umbrella companies move risk further up the chain. Where PAYE has not been operated correctly, HMRC guidance says the agency with the worker supply contract, or the end client where there is no agency, may be responsible for underpaid PAYE.
That changes the commercial risk.
It is no longer enough to say: "the umbrella company dealt with it" or "the payroll provider was responsible."
The real question is:
If HMRC reviewed your labour supply chain tomorrow, could you prove who employed the worker, who operated PAYE, who controlled the payment flow, and where liability sits?
HMRC has been increasingly direct about labour supply chain fraud and umbrella company non-compliance. Government guidance warns that organised labour fraud is used to avoid VAT, Income Tax and National Insurance. It also warns agencies and businesses using temporary labour that non-compliant arrangements can create tax liabilities, penalties, reputational damage and loss of business.
HMRC's published list of named tax avoidance schemes, promoters, enablers and suppliers has continued to grow. Industry payroll body CIPP has reported HMRC additions including Fortunes Payroll Ltd, T.U Pay Limited, Umbrella Contracts Limited, Evolve Payroll Ltd, Modus Umbrella Limited, Pay APL Limited, AIT Umbrella Limited, Real Payments Limited and Regis Limited.
The point is not that every umbrella company or payroll provider is a problem.
Many operate properly.
The point is that businesses can no longer afford weak evidence.
Payroll and outsourced administration failures are not theoretical either. The Register reported in March 2026 that the chair of Parliament's Public Accounts Committee questioned a major DWP shared services contract awarded to Capita after failings in Capita's administration of the Civil Service Pension Scheme.
That example is not the same as umbrella-company PAYE liability, but it shows the same board-level lesson: when payroll, pensions or labour administration breaks, the commercial fallout lands far beyond the back office.
So the board-level question is simple:
Can you evidence the whole chain?
That means:
the contract between the end client and agency
the contract between agency and umbrella or payroll provider
who employs the worker
who calculates PAYE and National Insurance
who actually pays the worker
what the worker sees on the payslip
whether the worker received the correct Key Information Document
whether deductions, margins and employer costs are clear
whether any offshore, loan, grant, advance, bonus, annuity, profit-share or "non-taxable" payment language appears anywhere
whether the supplier can evidence that PAYE is being operated correctly
If that evidence is missing, unclear or split across suppliers, your risk position may be weaker than you think.
Genius is offering a free PAYE Labour Supply Chain Health Check
Genius has been through a three-and-a-half-year HMRC inspection, and our systems came through approved.
That matters because this is not theory for us. We know what HMRC asks for. We know how long inspections can run. We know the difference between a neat sales promise and evidence that survives scrutiny.
We are now offering a free initial Labour Supply Chain PAYE Health Check for businesses that want to understand their risk before the 2026 rules bite.
You can send us:
your labour supplier contract
umbrella or payroll provider agreement
sample payslip flow
Key Information Document
invoice flow
worker onboarding process
supplier compliance statement
We will review the documents and tell you, in plain English:
where the PAYE responsibility appears to sit
where your evidence is strong
where the gaps are
what HMRC is likely to ask for
what you should tighten before April 2026
This is not a full legal opinion and it does not replace specialist tax advice. It is a practical first-pass health check from a team that has lived through HMRC scrutiny and built systems to withstand it.
This is for construction businesses, recruitment agencies, logistics firms, facilities companies, care providers, labour-heavy SMEs, and any business using umbrella, payroll intermediary, agency or subcontracted labour models.
The businesses that prepare now will have evidence.
The businesses that wait will have explanations.
And when HMRC comes asking, explanations are not as strong as clean contracts, clean payslips and a clean audit trail.
Get in touch with our team and send us your labour supply contracts, payslip flow and supplier paperwork. We will give you a free PAYE Labour Supply Chain Health Check and tell you where the risk sits....
