Joint and Several Liability (JSL) 2026: What You Need to Know

From 6 April 2026, significant changes to PAYE and National Insurance enforcement will take effect across the UK labour supply chain. These reforms — known as Joint and Several Liability (JSL) — will impact contractors, freelancers, umbrella companies, recruitment agencies, SMEs, and end-clients.

Understanding these changes early is essential.
At GR Ace Legal Compliance, I support individuals and organisations across all sectors to prepare with clarity, confidence and tailored legal guidance.

🔍 What Is Changing?

From April 2026, HMRC will have expanded powers to recover unpaid PAYE and NICs from any party involved in a supply chain, not solely from the umbrella company responsible for payroll.

This means:

  • Recruitment agencies may be liable
  • End clients may be liable
  • Any party in the chain may be held responsible, depending on HMRC’s assessment

The purpose of these reforms is to reduce non-compliance and protect workers from misleading or unsafe umbrella arrangements.

✔️ Who Is Affected?

These legislative changes apply to:

  • Contractors and freelancers
  • Umbrella companies
  • Recruitment agencies
  • SMEs and larger businesses
  • Any organisation supplying or engaging temporary or umbrella-employed workers

If you operate anywhere within a labour supply chain, the JSL rules apply to you.

⚠️ Why Choosing a Compliant Umbrella Company Matters

Government reviews have highlighted ongoing concerns within the umbrella sector, including:

  • Disguised remuneration schemes
  • Unlawful or hidden deductions
  • Misleading “high take-home pay” claims
  • Poor payroll transparency

Because JSL enables HMRC to pursue liability across the entire chain, choosing a reputable, compliant umbrella provider is essential.

Here are examples of well-established organisations in the industry that provide useful, compliance-focused resources:

Umbrella Companies & Industry Providers

  • Bishopsgate — transparent PAYE operations and strong compliance reputation
  • NumberMill — accountancy and payroll services with a compliance-driven approach
  • Clarity Umbrella — known for ethical, straightforward umbrella PAYE processes

These organisations offer valuable guidance and industry insights for individuals, contractors and businesses seeking compliance information.

🧩 How to Prepare — Practical Steps You Can Take Now

To reduce risk ahead of the 2026 JSL rollout:

  • Review your current umbrella or agency relationships
  • Request evidence of PAYE/NIC payments, audits or accreditations
  • Update contracts and onboarding processes to reflect the new rules
  • Avoid umbrellas promising “enhanced take-home pay” or unusual tax structures
  • Seek legal guidance early if anything feels unclear, non-compliant or high-risk

A little preparation now can prevent costly issues later.

🤝 The Right Support — From Multiple Trusted Sources

The recruitment and contractor sectors benefit from a range of specialist organisations that provide education, training and compliance updates.

Lawspeed, for example, offers:

  • Industry insights
  • Legislative updates
  • Compliance seminars
  • Recruitment-focused legal guidance

They are hosting a seminar in January 2026, view their Events page for further information. 

Whether you’re a contractor, freelancer, business owner or agency, you don’t have to navigate these changes alone.

 

Get in touch if I can help at www.gracelegal.net or DM me at @grace.legal2025 or contact me via info@gracelegal.net.