What does it mean for intermediaries & businesses?

Two different positions

An intermediary and an end client sit in the same chain but carry different duties. The client decides status; the fee-payer operates PAYE on the result. Confusing the two is how liability ends up unowned.

From April 2026, unpaid PAYE can also move up the chain, which makes the distinction a commercial question rather than an administrative one.

What an intermediary must do

• Pass the status determination statement down the chain unchanged.
• Operate PAYE where you are the fee-payer and the determination says inside.
• Keep evidence of what you received and when you passed it on.
• Check that the parties below you are doing the same, because their failure can become yours.

What a business must do

Assess each engagement individually and with reasonable care, issue the statement in writing with reasons, and answer a challenge within 45 days.

Small companies are outside the off-payroll rules, but the underlying IR35 legislation still applies to the worker’s own intermediary — being out of scope of one is not being out of scope of the other.

Where to get help

Most of the difficulty is in the chain rather than in any single assessment. Mapping it is the work that makes everything else answerable.