Following yesterday’s (13/06/25) meetings between HMRC and key industry stakeholders – including the FCSA, Saferec, the Temporary Labour Initiative, and Rebecca Sealey Harris – along with input from others who’ve engaged with HMRC and local MPs, we can confirm that HMRC’s current proposal is to introduce a Joint and Several Liability model.
In this short blog, Chris Bloor, our Director of Compliance, breaks down what this could mean:
“It’s important to remember that this still needs treasury approval, but based on what we currently understand:
- The employer’s reference number stays with the umbrella company;
- However, the lead agency (or the end client if no agency is involved) will be strictly liable for any tax shortfalls; and importantly,
- No statutory excuse will apply under this proposed model.
The aim? To drive accountability across the supply chain and reduce non-compliance risks in the labour market. It feels like a strong signal of HMRC’s commitment to compliance and transparency.
We expect confirmation on Legislation Day (‘L-day’) – likely mid-July – when HMRC will publish draft legislation and further guidance. We’ll be keeping a close eye and will share updates as they land.”
