What does it mean for intermediaries & businesses?

Who the rules reach

From April 2026 the responsibility for PAYE in a contractor supply chain no longer stops with the party that operates it. Where an umbrella company fails to account for tax, the liability can move up the chain to the agency or, where there is no agency, to the end client.

That is a change of exposure, not a change of process — the work is the same, but the consequences of a supplier getting it wrong are now yours as well.

What an intermediary should check

• Who operates PAYE at every step of the chain, in writing, not by assumption.
• Whether each supplier’s filings are current, and how you would know if they stopped being current.
• What your contracts say about indemnity, and whether the counterparty could actually meet it.
• Whether the workers in the chain can explain their own deductions — a chain that cannot is a chain nobody is checking.

What an end client should check

The end client’s exposure begins where the chain has no UK agency in it. In that case the client is the party HMRC looks to, and “we used a supplier” is not a defence.

The practical answer is to shorten the chain, or to know it well enough to describe it.

Where to start

Map the chain first. Most businesses discover at this point that they cannot name every party in it, and that is the finding — not a step on the way to one.