Aside from some tweaks to the purported umbrella companies section, there were no material changes to the joint and several liability (“JSL”) provisions published in July 2025, and we expect the Finance Bill to take a streamlined route through Parliament and receive Royal Assent without contention. As a recap, JSL allows HMRC to pursue PAYE and NI liability from the umbrella company and the agency holding the contract with the end client for the supply of the worker (ie the top tier agency, or Managed Service Provider). If there is no agency in the supply chain, the liability will fall on the end client.

This is a strict liability offence meaning there’s no statutory defence for an agency that acted reasonably or conducted due diligence before engaging an umbrella company. It will apply to all payments made on or after 6 April 2026.