Umbrella Joint & Several Liability (JSL) Risk Checker

For payments made on or after 6 April 2026, HMRC can recover unpaid PAYE and NICs from another party in an umbrella company labour supply chain. The rules sit in Chapter 11 of Part 2 ITEPA 2003 (sections 61Y to 61Z1), inserted by Finance Act 2026 section 24, with SI 2026/388. The umbrella company still operates PAYE — JSL changes who HMRC can collect from if it does not pay over.

No. The umbrella company remains your employer and still operates PAYE, so income tax, employee National Insurance, employee pension and any student loan come off your gross pay exactly as before. JSL is a recovery power aimed at the parties above the umbrella; it changes nothing in the arithmetic of a compliant payslip.

The PAYE liability falls on the relevant party: the agency closest to the end client in the chain. Where there is no such agency, where that agency is connected to the client within ITA 2007 s.993, or where it is not UK-resident, the end client carries it instead. The worker still remains responsible for their own personal tax position.

To payments made on or after 6 April 2026, the first day of the 2026/27 tax year. They apply where a worker is employed by an umbrella company, or by a purported umbrella caught by the anti-avoidance provisions in ESM2440. They do not apply where the worker is treated as employed only by the agency rules, the off-payroll working (IR35) rules, the managed service company rules or the salaried-members rules.

No. HMRC has stated explicitly: "If a scheme is not on the list, this does not mean it works or has HMRC approval." This tool surfaces red flags and helps you investigate further. It is not a substitute for professional advice and not a statutory defence.

No. The legislation contains no reasonable-care or due-diligence defence, and in our Q&A with HMRC (Q13) HMRC confirmed: "There is no statutory defence if relevant parties have undertaken due diligence checks." Liability arises regardless. Identifying problems early still matters, because it gives you the chance to act before HMRC issues a determination.

A business that claims to operate as an umbrella but does not actually employ workers the way a genuine umbrella would. The legislation treats the worker as employed by such an entity anyway, so JSL still applies. This is designed to stop avoidance by re-structuring. Full guidance is in ESM2440.

Frequently, and unpredictably. HMRC publishes additions at least monthly and usually more often: the snapshot embedded in this tool averages about five new entries a month, and 19 entries were added in December 2025 alone. This tool uses a fixed snapshot, so check the as-at date at the top and click through to the live HMRC list before acting on a clean result.

HMRC publishes and maintains the full Current list of named tax avoidance schemes, promoters, enablers and suppliers on GOV.UK. This tool checks your specific umbrella against a snapshot of that list as you type.

Your umbrella name is compared in your browser against an embedded snapshot of HMRC's named tax avoidance schemes list — 182 named entities plus 7 linked trading names — matched exactly, by close spelling and by substring. You then answer a short questionnaire about red-flag patterns in the pay arrangement, and a risk score out of 100 and an action checklist are generated locally. No data is sent to any server.