Despite doubts by some over whether the 'named' feel 'shamed,' HMRC's latest 'name and shame' list of firms linked to tax avoidance schemes is shining a light on the darker corners of the contractor marketplace.
And my key takeaway for contractors from the October 2025 edition is that, pleasingly, it seems that HMRC is getting better at exposing the tax arrangements that workers should avoid, writes Crawford Temple, CEO of compliance organisation Professional Passport.
The latest HMRC avoidance list is a timely reminder
October's online "List of named tax avoidance schemes…" is also a timely reminder that Disguised Remuneration remains a stubborn problem.
In fact, Disguised Remuneration (DR) continues to evolve despite years of successive governments' efforts with:
- Legislative tightening;
- Enforcement activity by HMRC, and;
- Public warnings by government bodies.
More and more disguised remuneration schemes posing as umbrella companies
In our role as the UK's largest independent assessor of payment intermediary compliance, we're seeing a sharp increase in disguised remuneration schemes attempting to badge themselves as 'umbrella companies.'
They falsely claim accreditation across many of the recognised standards in a bid to present themselves as compliant umbrella companies that contractors ought to use.
A surge in umbrellas that aren't umbrellas is no accident
Let's be clear — this sudden flurry of 'umbrellas that aren't proper umbrellas' is no coincidence.
The umbrella company legislation to be introduced from April 6th 2026 has, in effect, created a 'closing date' for these schemes.
The operators you see listed on HMRC's so-called 'naughty list,' i.e. those companies behind the schemes, know that once Joint and Several Liability (JSL) is implemented from 2026-27, agencies and end-clients will become jointly liable for unpaid tax where a non-compliant umbrella is involved.
That means their market will dry up.
Therefore, rogue operators are now doing everything they can to maximise their returns while they still can.
What does tax avoidance promoters going all out look like?
It means that, faced with the April 2026 cut-off that is the JSL rules, the rogues are:
- Chasing accreditation;
- Dressing up non-compliant models as legitimate, and;
- Aggressively targeting contractors and agencies alike.
The last-ditch 'cash-in' before Joint & Several Liability (JSL) bites
The umbrella company market has, unfortunately, harboured the architects of disguised remuneration schemes for far too long.
These operators thrive on complexity, confusion, and a lack of joined-up enforcement. While the new JSL rules should go a long way towards shutting them down, we are already seeing a last-ditch push from those looking to 'cash-in' before April 2026.
This surge in activity makes the next six months critical for agencies and the wider supply chain.
As JSL looms, what steps should recruitment agencies take?
Agencies should be reviewing their supply chains and reviewing their options for protecting themselves against the risks of JSL.
There are typically two main options available:
- So-called 'after the event' checks.
- Paying HMRC the PAYE liability directly.
Waiting until the JSL legislation bites will be too late
But as the final wording of the legislation is due on or after Autumn Budget 2025 on November 26th 2025, this publication should provide affected parties with the clarity to make decisions on migrating to what I'd call the 'new world' of compliance.
Taking action once that clarity emerges will help protect both agencies and their contractors from the financial and reputational fallout that could follow if they are caught on the wrong side of the new rules.
HMRC's 'name and shame' avoidance list is to be welcomed
But back to the now 200-strong 'naughty list.'
We welcome HMRC's continued efforts to clamp down on avoidance, and naming those involved in promoting or enabling these schemes is an important step.
However, transparency from the Revenue must be backed by swift, visible enforcement. HMRC has long held a wealth of data that could have been used more effectively to identify and close down these schemes earlier. The tax authority dragged its feet for far too long, and we are where we are.
Disguised Remuneration schemes are exploiting a final window
Our organisation has always advocated for a fair, transparent, and compliant contractor umbrella company sector — one that protects workers and gives agencies confidence.
But right now, the sector is under pressure.
DR schemes are exploiting the final window before regulation tightens, and the risk of unwitting engagement with a non-compliant provider has never been higher.
Professional Passport's message ahead of JSL from 2026/27
Our message to agencies, end-clients, and contractors is simple: don't assume that an umbrella claiming to be accredited is safe.
Instead, forensically check the details, ask for evidence, and understand how workers are being paid.
The bigger picture, of course, is that the clock is ticking. April 2026 will bring much-needed reform to working through an umbrella company, but it will also bring accountability. Those who act early will protect themselves and their workers. Those who wait could find themselves holding the bill.
