Are we about to see the first JSL claims against recruitment agencies?

Recent reports of HMRC winding-up petitions against umbrella companies raise some serious questions for the recruitment sector.

With the new JSL regime in force since 6 April 2026, recruitment agencies could now find themselves facing substantial PAYE liabilities arising from umbrella company non-compliance.

The real concern? Even agencies that have undertaken due diligence, relied on compliance accreditation and secured contractual indemnities may still face exposure.

Could we now be approaching the first wave of HMRC recovery demands, followed by contractual disputes and litigation across the supply chain?

At C2E Law, we examine the potential legal consequences and why recruitment agencies should be reviewing their exposure now.